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Home My WebLink About20202108.tiff COLORADO jelp44.00 Department of Public Health Er Environment RECEIVED Weld County - Clerk to the Board JUN 0 8 2020 1150O St PO Box 758 COMMISSIONERS Greeley, CO 80632 June 1, 2020 Dear Sir or Madam: On June 2, 2020, the Air Pollution Control Division will begin a 30-day public notice period for CCRP Operating Inc. - True Ranch Fee 2326H. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator - 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director ; * CC/- PLC TM, H LC 5 T), nn wb( ic (Rev Pwcom/CHI ER IC 15) 2020-2108 01107010 Olt 1Hl@ cMY CM Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: CCRP Operating Inc. - True Ranch Fee 2326H - Weld County Notice Period Begins: June 2, 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: CCRP Operating Inc. Facility: True Ranch Fee 2326H Welt Production Facility NENE of Section 23, Township 12N, Range 65W Weld County The proposed project or activity is as follows: CCRP Operating Inc. is requesting permit coverage for six (6) crude oil storage vessels, four (4) produced water storage vessels, natural gas venting from two (2) three- phase separators and hydrocarbon liquid loadout at a new synthetic minor oil and gas well production facility located in the ozone attainment area. 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 19WE0770, 19WE0771, 20WE0017 Et 20WE0018 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/ai r-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: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment COLORADO je „,..,,,,_:, Department of Public 1 I E Health 6 Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (COLORADO - Department of Public `D.4 Health b Environment - 1. COLORADO CAir Pollution Control Division COMHE Department of Public Heath&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0770 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: True Ranch Fee 2326H Plant AIRS ID: 123/A070 Physical Location: NENE SEC 23 T12N R65W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Two (2) Enclosed Six (6) 500 barrel fixed roof crude oil Combustors (Make: TK 1-6 001 storage vessels connected via liquid Crimson Energy, manifold. Model: CE-1000, SN: CE1000-CCRP-0318 a CE1000-CCRP-0218 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 Page 1 of 13 C x,y. 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 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 II I.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type TK 1-6 001 --- 2.5 28.3 11.2 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice Page 2 of 13 r•"% COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado (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 Two (2) Enclosed Combustors (Make: TK 1-6 001 Crimson Energy, Model: CE-1000, SN: VOC and HAP CE1000-CCRP-0318 It CE1000-CCRP-0218 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, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID Crude Oil TK 1-6 001 248,475 barrels Throughput The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 10. On a minimum of an hourly basis, the owner or operator shall monitor the control device for the presence of a pilot light and an operational auto-igniter. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto-igniter, the emissions from the crude oil storage vessels shall be assigned a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years, and a summary of monthly pilot light downtime and crude oil throughput during pilot light downtime shall be provided to the division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 3 of 13 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 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 17. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 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 18. Within one hundred and eighty days (180) of the issuance of this permit, the owner or operator shall conduct an initial source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98%for VOC for each operating scenario. During the test, the owner or operator must measure: Page 4 of 13 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 • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • crude oil throughput; • volume of crude oil storage vessel waste gas routed to the enclosed combustors; • combustion chamber temperature; • pilot gas flow rate; • crude oil waste gas heat content at the inlet of the control device; • crude oil waste gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M, The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30)days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. Results of the initial compliance test must be submitted to the Division as part of the self-certification process. If the results of the initial compliance test do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 19. At least once every 12 months, the owner or operator shall conduct a source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario. Periodic testing shall be conducted at a minimum of at least one hundred and eighty (180) days apart. During the test, the owner or operator must measure: Page 5 of 13 -r, COLORADO 40 w Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • crude oil throughput; • volume of crude oil storage vessel waste gas routed to the enclosed combustors; • combustion chamber temperature; • pilot gas flow rate; • crude oil waste gas heat content at the inlet of the control device; • crude oil waste gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may,be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. If the results of the periodic compliance tests do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Records of annual compliance tests must be maintained by the owner or operator for a minimum of five (5) years and made available to the Division for inspection upon request. (Regulation Number 3, Part B., Section III.G.3) ALTERNATIVE OPERATING SCENARIOS 20. The control device may be replaced with a like-kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like-kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this Page 6 of 13 COLORADO gip 4%060 Air Pollution Control Division Department of Public Health Es Environment Dedicated to protecting and improving the health and environment of the people of Colorado construction permit. The owner or operator shall maintain a log on-site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 21. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternative Operating Scenario and has replaced the control device. 22. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternative Operating Scenario provision, the owner or operator shall conduct a source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • crude oil throughput; • volume of crude oil storage vessel waste gas routed to the enclosed combustors; • combustion chamber temperature; • pilot gas flow rate; • crude oil waste gas heat content at the inlet of the control device; • crude oil waste gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test Page 7 of 13 Cr*: .� COLORADO • Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. If the results of the periodic compliance tests do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Records of compliance tests must be maintained by the owner or operator for a minimum of five (5) years and made available to the Division for inspection upon request. (Regulation Number 3, Part B., Section III.G.3) ADDITIONAL REQUIREMENTS 23. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 24. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). Page 8 of 13 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 GENERAL TERMS AND CONDITIONS 25. 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. 26. 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. 27. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 28. 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. 29. 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. 30. 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. 31. 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. Page 9 of 13 C �: �.- COLORADO Air Pollution Control Division Nftief Department of Public Health b Environment . Dedicated to protecting and improving the health and environment of the people of Colorado By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to CCRP Operating Inc. Permit for six (6) crude oil storage vessels at a new synthetic minor well production facility. Page 10 of 13 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 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 4,172 84 Toluene 108883 2,971 60 001 Ethylbenzene 100414 848 17 Xylenes 1330207 1,550 31 n-Hexane 110543 95,058 1,902 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 NOx 1.96x10-2 1.96x10-2 AP-42 Chapter 13.5 CO 8.95x10-2 8.95x10-2 AP-42 Chapter 13.5 VOC 11.357 2.271 x10-1 Page 11 of 13 COLORADO 40 %Tor 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 1.679x10-2 3.358x10-4 108883 Toluene 1.195x10-2 2.391 x1O4 ProMax it EPA 100414 Ethylbenzene 3.412x10-3 6.824x10-5 Tanks 4.09D 1330207 Xylene 6.238x1O3 1.248x10-4 110543 n-Hexane 3.826x10-1 7.651x10-3 Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control efficiency of 98%.The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with ProMax and EPA Tanks 4.09d.The pressurized liquid sample was obtained from the outlet of the three-phase separators on 10/23/2019 and used as an input for the ProMax simulation to estimate flash emissions. The sample temperature and pressure are 138°F and 51 psig respectively. Working and breathing emissions were estimated using EPA Tanks 4.09d. This simulation uses Denver, CO for the location basis and crude oil (RVP 5) for the liquid basis. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 tb/MMBtu and 0.31 lb/MMBtu respectively)in the table above were converted to units of tb/bbl using a GOR of 115.13 scf/bbl and heat content of 2507.13 Btu/scf. Actual NOx and CO emissions must be calculated by multiplying the emission factors in the table above by the crude oil throughput during enclosed combustor operation. Actual VOC and HAP emissions must be calculated using the following equation: VOC&HAP Actual Emissions = [(Vtotal —VPLX) X (EFcontrotied�] + [(VpLX)X (EFuncontrolled)] Where: • VOC Ft HAP Actual Emissions in the equation above have units of lbs/month • Vtotal =Total monthly volume of crude oil (bbl/month) • VPLX=Total monthly volume of crude oil while the pilot light is not lit/operational (bbl/month) • EFcontrolled = Controlled emission factor listed in the table above (lb/bbl) • EFuncontrolled = Uncontrolled emission factor listed in the table above (lb/bbl) 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane and Total HAP Page 12 of 13 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 PSD Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A'- Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 13 of 13 C r COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0771 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: True Ranch Fee 2326H Plant AIRS ID: 123/A070 Physical Location: NENE Section 23 T12N R65W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description Two (2) Enclosed Combustors (Make: ECD 1 Et 2 002 Natural gas venting from two (2) three- Crimson Energy, phase separators. Model: CE-1000, SN: CE1000-CCRP-0318 Et CE1000-CCRP-0218) This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may Page 1 of 15 4..C y.,,,....... , COLORADO irriAir Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at www.cotorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type X ECD 1 Et 2 002 --- 5.1 36.2 23.1 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. 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 Page 2 of 15 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Emissions from the three-phase separators are routed to two (2) enclosed combustors ECD 1 a 2 002 (Make: Crimson Energy, Model: CE-1000, VOC and HAP SN: CE1000-CCRP-0318 ft CE1000-CCRP- 0218) 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, Section II.A.4.) ) Process Limits Equipment ID AIRS Process Process Parameter Annual Limit Point Natural gas vented from 01 the three-phase 90.6 MMSCF ECD 1 Et 2 002 separators and routed to the enclosed combustors 02 Combustion of pilot light 0.4 MMSCF gas The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. Page 3 of 15 COLORADO jetur„,....er, Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people o Colorado 10. The owner or operator must continuously (i.e. at least once every 15 minutes) monitor and record the volumetric flow rate of natural gas vented from the three-phase separator(s) and routed to the enclosed combustors using an operational continuous flow meter(s). The flow meter(s) must be installed, calibrated and maintained according to the manufacturer's specifications: The flow meter(s) must accurately measure and record the maximum and minimum potential rates of natural gas vented from the three-phase separators. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 11. On a minimum of an hourly basis, the owner or operator shall monitor the control device for the presence of a pilot light and an operational auto-igniter. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto-igniter, the flow volume from the three-phase separators shall be assigned a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years, and a summary of monthly pilot light downtime and vapor flow during pilot light downtime shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 15. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant Page 4 of 15 C COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 & MAINTENANCE REQUIREMENTS 17. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OftM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 18. The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from the three-phase separators. The sample shall be analyzed for gross (higher) heat content and total VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. The sample shall be collected prior to the inlet of the enclosed combustors and prior to being combined with any other stream. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self-certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 19. Within one hundred and eighty days (180) of the issuance of this permit, the owner or operator shall conduct an initial source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98%for VOC for each operating scenario. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; Page 5 of 15 CFz COLORADO qta Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • flow rate of natural gas vented from the three-phase separators and routed to the enclosed combustors • combustion chamber temperature; • pilot gas flow rate; • Gas heat content at the inlet of the control device; • Gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. Results of the initial compliance test must be submitted to the Division as part of the self-certification process. If the results of the initial compliance test do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. (Regulation Number 3, Part B., Section III.G.3) Periodic Testing Requirements 20. On an annual basis, the owner or operator must complete a site specific extended gas analysis ("Analysis") of the natural gas vented from the three-phase separators. The sample shall be analyzed for gross (higher) heat content and total VOC, benzene, toluene, ethylbenzene, xylenes, n-hexane, and 2,2,4-trimethylpentane (weight fraction) of this emission stream. The sample shall be collected prior to the inlet of the enclosed combustors and prior to being combined with any other stream. Periodic sampling shall be conducted at a minimum of at least one hundred and eighty (180) days apart. Results of the Analysis must be used to calculate site-specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in Page 6 of 15 --r.•r�.- COLORADO 10 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the'"Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 21. At least once every 12 months, the owner or operator shall conduct a source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario. Periodic testing shall be conducted at a minimum of at least one hundred and eighty (180) days apart. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • flow rate of natural gas vented from the three-phase separators and routed to the enclosed combustors • combustion chamber temperature; • pilot gas flow rate; • Gas heat content at the inlet of the control device; • Gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M, The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. If the results of the periodic compliance tests do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed Page 7 of 15 C ., ,,,, ...x -, 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 to by the Division, a request for permit modification to address these inaccuracies. Records of annual compliance tests must be maintained by the owner or operator for a minimum of five (5) years and made available to the Division for inspection upon request. (Regulation Number 3, Part B., Section III.G.3) ALTERNATIVE OPERATING SCENARIOS 22. The control device may be replaced with a like-kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like-kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on-site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 23. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternative Operating Scenario and has replaced the control device. 24. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternative Operating Scenario provision, the owner or operator shall conduct a source compliance test on this emissions unit to measure the emission rate(s) for the pollutants listed below in order to demonstrate compliance with the emissions limits contained in this permit and to demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario. During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M;) using EPA approved methods; • mass emission rates of VOC at the outlet of the control device (Mo) using EPA approved methods; • mass emission rates of oxides of nitrogen at the outlet of the control device using EPA approved methods; • mass emission rates of carbon monoxide at the outlet of the control device using EPA approved methods; • flow rate of natural gas vented from the three-phase separators and routed to the enclosed combustors • combustion chamber temperature; • pilot gas flow rate; • Gas heat content at the inlet of the control device; • Gas composition at the inlet of the control device. The destruction efficiency (DE) for VOC must be calculated using the following equation: Page 8 of 15 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado DE (%) = 100*(Mi-Mo)/Mi The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. If the results of the periodic compliance tests do not demonstrate compliance with the emission limits contained in this permit or do not demonstrate a minimum destruction efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Records of compliance tests must be maintained by the owner or operator for a minimum of five (5) years and made available to the Division for inspection upon request. (Regulation Number 3, Part B., Section III.G.3) ADDITIONAL REQUIREMENTS 25. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. 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. Page 9 of 15 ,:, COLORADO 0 40 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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. 26. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 27. 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. 28. 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. 29. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 30. 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. Page 10 of 15 CCOLORADO IV Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 31. 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. 32. 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. 33. 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issued to CCRP Operating Inc. Issuance 1 This Issuance Permit for natural gas venting from two (2) three-phase separators at a new synthetic minor oil and gas well production facility. Page 11 of 15 COLORADO >itie Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 8,177 164 Toluene 108883 9,093 182 ECD 1 Et 2 002 Ethylbenzene 100414 1,481 30 Xylenes 1330207 3,807 77 n-Hexane 110543 93,680 1,874 Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 12 of 15 Cx: COLORADO 0 Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Process 01: Natural gas venting from three-phase separators Weight Uncontrolled Controlled CAS # Fraction of Pollutant Emission Emission Source Gas (%) Factors Factors (lb/MMscf) (lb/MMscf) --- --- NOx 111.42 111.42 AP-42 Chapter 13.5 --- --- CO 507.97 507.97 AP-42 Chapter 13.5 --- 51.364 VOC 39,962.28 799.25 Gas Analysis 71432 0.116 Benzene 90.25 1.81 Gas Analysis 108883 0.129 Toluene 100.36 2.01 Gas Analysis 100414 0.021 Ethylbenzene 16.34 3.27x101 Gas Analysis 1330207 0.054 Xylene 42.01 8.4x10-1 Gas Analysis 110543 1.329 n-Hexane 1,033.99 20.68 Gas Analysis Note: The controlled emissions factors for this point are based on the enclosed combustors control efficiency of 98%.The site-specific VOC and HAP emission factors in the table above are based on the molecular weight (29.487 lb/lbmol) and composition (weight%) from a site-specific extended gas analysis and the displacement equation (EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10). The site-specific extended gas analysis was obtained from the outlet of a temporary three-phase separator at the True Ranch Fee 2326H facility on 02/11/2019. The sample pressure is 99.57 psig. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) in the table above were converted to units of lb/MMscf using a heat content of 1,638.6 Btu/scf. Actual NOx and CO emissions must be calculated by multiplying the emission factors in the table above by the total metered volume of natural gas vented to and combusted by the enclosed combustors. Actual VOC and HAP emissions must be calculated using the following equation: VOC&HAP Actual Emissions = [(Vtotal —VPLx) X (EFcontrolled)1 + [(VPLx) X (EFuncontrolled)] Where: • VOC it HAP Actual Emissions in the equation above have units of lbs/month • Vtotal =Total metered monthly volume of gas vented from the three-phase separators and sent to the control device during the month (MMscf/month) • VPLx=Total metered volume of gas vented from the three-phase separators and sent to the control device while the pilot light is not lit/operational (MMscf/month) . • EFcontrolted = Controlled emission factor listed in the table above for Process 01 (lb/MMscf) • EFuncontrolted = Uncontrolled emission factor listed in the table above for Process 01 (lb/MMscf) Process 02: Combustion of pilot light gas Page 13 of 15 C V.' COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Emission Source Factors Factors (lb/MMscf) (lb/MMscf) NOx 111.42 111.42 AP-42 Chapter 13.5 CO 507.97 507.97 AP-42 Chapter 13.5 VOC 8.84 8.84 AP-42 Chapter 1.4 Table 1.4-2 Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,638.6 Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4 emission factor by a ratio of 1,638.6 Btu/scf to 1,020 Btu/scf. Actual emissions must be 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 22 scf/hr. There are a total of two combustors used to control emissions from the three- phase separators. As a result, the total pilot light gas fuel flow is 44 scf/hr. Total actual emissions are calculated using the sum of emissions resulting from venting of natural gas from the three-phase separators and combustion of waste gas (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 facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, &t Total HAP PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Page 14 of 15 COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 15 of 15 Cao 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 CONSTRUCTION PERMIT Permit number: 20WE00 1 7 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: True Ranch Fee 2326H Plant AIRS ID: 123/A070 Physical Location: NENE SEC 23 T12N R65W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Four (4) 500 barrel fixed roof produced Enclosed PWTANKS 003 water storage vessels connected via liquid Combustor(s) manifold. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 9 r•:x COLORADO 410 Akiw Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type PWTANKS 003 --- 1.0 3.6 4.6 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 9 Cr COLORADO _ Air Pollution Control Division Department of Public Heath&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID PWTANKS 003 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID PWTANKS 003 Produced Water 543,154 barrels Throughput 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. Page 3 of 9 COLORADO 40 wily Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 this point, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or Page 4 of 9 COLORADO Air Pollution Control Division 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. 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. 20. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with Page 5 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 representations made by the owner or operator or owner or operator's agents. It is validonly for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to CCRP Operating Inc. Permit for four (4) produced water storage vessels at a new synthetic minor oil and gas well production facility. Page 6 of 9 j� -r,•:�,.- COLORADO y Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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 3,802 191 003 n-Hexane 110543 11,950 598 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 003: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 3.66x10-3 3.66x10-3 AP-42 Chapter 13.5 CO 1.67x10-2 1.67x10-2 AP-42 Chapter 13.5 VOC 2.62x10-1 1.31 x10-2 CDPHE PS Memo 14-03 71432 Benzene 7.0x10-3 3.5x1O4 CDPHE PS Memo 14-03 Page 7 of 9 r• COLORADO MP. WorAir 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 110543 n-Hexane 2.2x102 1.1x103 CDPHE PS Memo 14-03 Note: The controlled emissions factors for this point are based on the enclosed combustors control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-03 for produced water storage vessels in Weld County. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) were converted to units of lb/bbl using a heat content of 1,496 Btu/scf and gas-to-water ratio (GWR) of 36 scf/bbl. Actual emissions must be calculated by multiplying the emission factors in the table above by the produced water throughput. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane Et Total HAP PSD Synthetic Minor Source of: VOC MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source ' Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD Page 8 of 9 C10 00LORADO -ib_ Air Pollution Control Division Department of Public Health b 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 9 of 9 COLORADO 40 >� Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE00 1 8 Issuance: 1 Date issued: Issued to: CCRP Operating Inc. Facility Name: True Ranch Fee 2326H Plant AIRS ID: 123/A070 Physical Location: NENE SEC 23 T12N R65W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description Hydrocarbon liquid loadout from Vapor Balance and LOAD1 004 storage vessels to tank trucks using Enclosed Combustor(s) submerged 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 (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify Page 1 of 11 COLORADO 10 -Nrif Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 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: Equipment ID AIRS Tons per Year Emission Point PM2.5 NO,t VOC CO Type LOAD1 004 --- 0.1 0.7 0.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 11 r•.�.� COLORADO Air Pollution Control Division Department of Public Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants Controlled ID Point LOAD1 004 Vapor Balance and Enclosed VOC and HAP Combustor(s) 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 rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment AIRS Process Parameter Annual Limit ID Point LOAD1 004 Hydrocarbon Liquid 248,475 barrels Loaded 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) Page 3 of 11 r*:� COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the hearth and environment of the people of Colorado 12. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 13. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 14. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, 15. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. Page 4 of 11 Cy,y.:. COLORADO itiv Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 16. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. 17. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 18. 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 19. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&tM 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 20. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements Page 5 of 11 C r.•: � COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 21. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 22. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1)ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50%or five(5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 23. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 24. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 6 of 11 Cif:. COLORADO iiire Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in 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. 26. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 27. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 28. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 29. Section 25-7-114.7(2)(a), C.R.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. 30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Page 7 of 11 g ,� ,'� COLORADO � Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit Engineer Permit History Issuance Date Description Issued to CCRP Operating Inc. Issuance 1 This Issuance Permit for hydrocarbon liquid loadout at a new synthetic minor oil and gas well production facility. Page 8 of 11 COLORADO Air Pollution Control Division Department of Public Health Er 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 45 3 004 n-Hexane 110543 398 20 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 004: Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl NOx 1.80x104 1.80x10-4 AP-42 Chapter 13.5 CO 8.19x10-4 8.19x10-4 AP-42 Chapter 13.5 Page 9 of 11 COLORADO 10 miimoP Air Pollution Control Division Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled Pollutant CAS # Emission Emission Source Factors Factors lb/bbl lb/bbl VOC 1.04x1O1 5.2x10-3 CDPHE PS Memo 14- 02 n-Hexane 110543 1.60x10-3 8.0x10-5 CDPHE PS Memo 14- 02 Note: The controlled emissions factors for this point are based on the enclosed combustors control efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-02 for crude oil loadout. The AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively)were converted to units of lb/bbl using a heat content of 2,507 Btu/scf and gas-to-oil ratio (GOR) of 1.054 scf/bbl. Actual emissions must be calculated by multiplying the emission factors in the table above by the hydrocarbon liquid loadout throughput. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane Et Total HAP PSD Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the 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 10 of 11 C , ,,,,...z.v.k• 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 MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 8: 402648 Received Date: 7/19/2019 Updated application received 12/31/19 Review Start Date: 4/27/2020 Original review started by J.Ricci on 10/14/19 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENE 23 12N 65 Plant AIRS ID: A070 Facility Name: True Ranch Fee 2326H 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 (Leave blank unless APCD Emissions Source Type Equipment Name Action Engineering Control? APCD has already # Required? Remarks has already assigned) assigned) Permit Initial 001 Crude Oil Tank TK 1-6 Yes 19WE0770 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc.is requesting permit coverage for several new sources at a synthetic minor oil and gas well production facility located in the ozone attainment area.With this application,the operator is requesting traditional permit coverage for crude oil storage vessels,-natural gas venting from separation equipment, produced water storage vessels and hydrocarbon liquid loadout.The operator is also requesting GP02 coverage for one(1)SI RICE.This analysis only evaluates the crude oil storage vessels. This source is APEN required because uncontrolled requested VOC emissions are greater than 2 tpy(CO AQCC Regulation 3,Part A,Section II.B.3.a,).Additionally, the source is permit required because uncontrolled requested VOC emissions from all APEN required sources at the facility are greater than 5 tpy(CO AQCC Regulation 3,Part B,Section II.D.3.a.). Public comment is required for this source because new synthetic minor limits are being established and the change in VOC emissions is greater than 50 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 0000 0 0 Title V Operating Permits(OP) 00000 000 Non-Attainment New Source Review(NANSR) ❑ 0 Is this stationary source a major source? If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 0 000 0 0 Title V Operating Permits(OP) 0000 0 ❑ ❑ 0 Non-Attainment New Source Review(NANSR) 0 0 Section 01-Administrative Information (Facility AIRS ID: 123 A070 001 County Plant Point Section 02•Equipment Description Details Storage Tank Liquid Crude Oil Detailed Emissions Unit 51x(6)500 barrel fixed roof crude all storage veuels connected via liquid manifold. Description: Emission Control Device Two(2)Enclosed Combustors(Make:Crimson Energy,Model:CE-1000,SN:CE1000-CCRP-0318&CE1000-CCRP-0218) Description: Requested Overall VOC&HAP Control Efficiency%: 98.0 Limited Process Parameter IUib°e:-,', qd; Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= 207,062.0 Barrels(hbp per year Requested Permit Limit Throughput= 248,475.0 Barrels(bbl)per year Requested Monthly Throughput= Barrels(bbl)per month Potential to Emit((PTE)Condensate Throughput= 248,475.0 Barrels(bbl(per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2507.1 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 115.127 scf/bbl Actual heat content of waste gas routed to combustion device= . o, I MMBTU per year Requested heat content of waste gas routed to combustion device= ..... MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= ... MMBTU per year Control Device Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf MMBTU/yr Section 04-Emissions Factors&Methodologies ProMax Flow Rate 365.00 bbl/year EPA Tank Flow Rate 41,41250 bbl/year W&B Gas Pollutant Flash Gas(lb/hr) Weight% (lb/year) VOC 0.469200491 83.1851261 3977.11 Benzene 0.000693614,. Toluene 0400493877.-. 0.0875601 Ethylbenzene 0400140971 04249929 Xylenes 0.000257735 0.0456941 n-Hexane 0.0158054 260215 2,2,4-TMP 0 '. 0 .0 Will this storage tank emit flash emissions? Emission Factors Crude Oil Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Crude Oil (Crude Oil Throughput) Throughput) VOC 113568 Site Specific E.F.(Includes flash) Benzene 1.679E-02 Site Specific E.F.(Includes flash) Toluene 1.195E02 .,-_ Site Specific E.F.(Includes flash) Ethylbenzene 3.412E.03 Site 5poelic E.F.(Includes flash) Xylene 6.238E-03 Site Specific E.F.(Includes flash) n-Hexane 3.826E-01 Site Specific E.F.(Includes flash) 224 TMP 0.0000 -. Control DeWce Uncontrolled Uncontrolled Pollutant )Ib/MMBtu) (lb/bbl) Emission Factor source (waste heat (Crude Oil • combusted) Throughput) PM10 0.0075 7-.. AP-42Table 1.4.2(PM10/FM.2.5) PM2.5 0.0075 AP-42 Table 1.4.2(PMIO/PM.2.5) SOx 0.0006 = AP-02 Table 1.4-2(SO4) NOx 0.0680 11 AP-42 Chapter 13.5 Industrial Flares(NO4) CO 0.3100 AP-42 Chapter 13.5 Industrial Flares(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant )Ib/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 PM2.5 SOx NO4 VOC 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) (tans/year) (tons/year) (tons/year) (tans/year) (Ibs/month) PM10 :._ PM2.5 :. _.__ sox )1 0.1 900 :438 =.03? c VOC 1410.945 115-7'15 2,14,:45 13_1 • CO 11.117 5._04 )o- 11,101 11.11? -. Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) fibs/year) (Ibs/year) (Ibs/year) (Ibs/year) Benzene _._03 .___ 41711:4 93.431 Toluene \l7 _1 .1.924 5°.401 Ethylbenzene ..C-.. .p__ 041 Le.41. Xylem - :_:31 1.191 11 __ n-Hexane _ -421 10^3 __ 224 TMP 11 442 „__ 11_ 2 of 4 - C:\Users\hslaught\Desktop\1234070\19WE0770.CP1 Section 06-Reeulatary Summary Analysis Regulation 3,Parts A,B .. Regulation 7,Part D,Section I.C,D,E,F Regulation 7,Part D,Section I.G,C Regulation 7,Part D,Section II.B,Cl,. C.3 Regulation 7,Part D,Section II.C.2 .... Regulation 7,Part D,Section Il.C.4.a.(i) Regulation 7,Part D,5ection ll.C.4.a.(ii) Regulation 6,Part A,NSPS Subpart Kb Regulation 6,Part A,NSPS Subpart 0000 ... .. NSPS Subpart 0000a Regulation 8,Part E,MACT Subpart HH .. .-. , (See regulatory applicability worksheet far detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to estimate emissions? tre If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than qual to 20 tons VOC per year OR are the uncontrolled actual or requested emissions fore condensate storage tank estimated to be greater than or equal to 80 tpy? N/A-the operator developed site specific emission factors. If yes,the permit will contain en"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? iorottAti If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample should be considered representative which generally means site-specific and collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an older' site-specific sample. If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain initial and periodic compliance testing In accordance with PS Memo 20-02 Section 06-Technical Analysis Notes L According to the APEN,two welts produce to this facility.The names and API numbers of the wells is as follows:(i)Name:True Ranch Fee 202-232614,API Number:05-123-47411;(d)Name:True Ranch Fee 502- 23260,API Number,05-123-47013.According to COGCC data,the True Ranch Fee 202-2326H well has not begun production.The True Ranch Fee 502-2326H well was fractured in December 2018 and began production in January 2019.COGCC also lists an average API gravity of less than 40.As annuli,the operator's classification of the liquid m crude oil is appropriate. 2.The operator has requested a 98%control efficiency for the two enclosed combustors used to control emiss ons fromthis source.It should be noted that the enclosed combustors are used to control emissions from the separators,produced water storage vessels and hydrocarbon loadout sources aswell.However,the operator has only requested a 98%control effidency for the separators and crude oll storage vessels. This simplifies the initial and ongoing compliance test since the number of scenarios that need to be tested is reduced.The operator is still required to conduct a rest that encompasses each normal operating scenario in order to demonstrate compliance with the emission limits for each source requesting 98%control and demonstrate the source is capable of meeting the requested destruction efficiency ataR times.The permit condition will be structured in a manner to account for these scenarios.It should be noted that the.operator Indicated that they are capable of isolating the separator gas from the crude oil storage vessel gas This capability will allow the operator to differentiate the emissions associated with the crude oil storage vessels from those associated with the separators.The stack testing protocol should take advantage of this capability in order to demonstrate compliance with the individual emission limits for each source and to demonstrate 98%destruction efficiency during each normal operating scenario. 3.Since the enclosed combustors are used to control multiple sources at this facility,including the crude oil storage vessels,separators,produced water storage vessels,and readout,the pilot light emissions are grouped with the highest emitting source that is controlled by the common control d ice.In this case,the three-phase separators are the highest emitting source.Therefore pilot light emissions are evaluated in the analysis for that source(19WE0771.CP1).Pilot light emissions willnot be double counted with this analysts. 4.The operator developed site specific emission factors through the use of a site specific sample,ProMax and EPA Tanks,The site specific sample was used as an input for the ProMeo simulation that was used to calculate the flash emissions from the storage vessels.The sample used In the simulation was obtained from the outlet of the three.phaseseparators at this facility on 10/23/2019.The sample temperature and pressure are 138°F and Si psig,The mbient pressure specified in the ProMax simui h n is12.2 psia In order to estimate working and breathing emissions,the operator utilized EPA Tanks.4.09d.This simulation was designed for one storagemessel.Therefore,the throughput specified In the simulation is 1/6 the total requested throughput of 248,475 661/year,The operator also specified the location as Denver,CO and the liquid as crude oil(RVP 5).While it ispreferable to use the same simulation for both flash and working and breathing emissions,EPA T ks is still an accepted method for estimating working and breathing emissions.Additionally,the input values specified in the EPA Tanks simulation by the operator were deemed acceptable.Therefore,the EPA Tanks simulation was accepted in lieu of the Tank toss Stencil in ProMex. The results of the simulations along vnth the calculation methods used to estimate the emission factors are available forreview in Section 04 above. 5.Since EPA Tanks 4.09d does not calculate the volume of working and breathing gas,the following equation was used to estimate the gat-to-oil rays(HOR)of the working and breathing portion of emissions: (3977.111b/year)/(50lb/bmol)"(379 scf/ibmol)/(0.831851261(/(41412.5 bbl/year)=0.8752040231 scf/hbl..Using this information in conjunction with data provided.by ProMax,the total GOR was calculated as fohows.10.97513-10231 ecf/bbl)e(0.0 0 01142 5 2 MMSCF/dey)e(1000000 scf/MMSCF)'(365 day/year)/(365 bbl/year)=115.127104 scf/hbl. 6.The:permit will not contain initial or periodic opacity testing for the enclosed combustor(s)because the O&M plan approved for this rce requires periodic visible emissions observations of the enclosed combustor(s). 7.The site specific sample used to develop site specific emission factors in this application was obtained on 10/23/19.This is within one year of application submittal and wasobtained after the current active well began producing.As a result,the permit will not contain an initial sampling requirement in order re confirm the emission factors.In the event the other well(05-123.47411)at this facility begins producing,the next engineer should confirm the initially approved emission factors are still representative.Some Rectorate consider include the formation fromwhich the well produces,the well depth and the API gravity of the fluid produced.If these parameters match with the current producing well(05-123-47413.then the initttl sample is likely still representative of actual emissions.If these parameters do not match,the operator should likely obta ore current sample in order to confirm the originally approved emission factors remain accurate or conservative.. B.The heat content used to calculate combustion emissions was obtained from the ProMax simulation.While working and breathing emssions typically have a higher heat content than the flash emissions,the mi nimal Increase in heat content would not result in a noticeable change in NOe and CO emissions.Asa result,the heat content calculated for the flash portion of emissions was deemed acceptable for the entire was gas stream and therefore used to calculate combustion emissions. 9.The operator was provided with a draft permit and APES redline to review prior to public comment.The operator reviewed both d uments and expressed they had no comments. Section 09-5CC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control%Units 01 E3xx,lti - - dYnnr BFea PM10 _ b/1,000 gallons Crude Oil throughput PM2.5 .. b/1,000 gallons Crude Oil throughput SOx T 6/1,000 gallons Crude Oil throughput NOx -. C b/1,000 gallons Crude Oil throughput VOC _ 6/1,000 gallons Crude Oil throughput CO _._ 6/1,000 gallons Crude Oil throughput Benzene ex 6/1,000 gallons Crude Oil throughput Toluene ,.. b/1000 gallons Crude Oil throughput Ethylbenzene 6/1,000 gallons Crude Oil throughput Kylene tvt 6/1,000 gallons Crude Oil throughput n-Hexane ...._ aS 6/1,000 gallons Crude Oil throughput 224 TMP .n 6/1,000 gallons Crude Oil throughput 3 of C:\Users\hslaught\Desktop\123A070\19WE0770.CP1 • Storage Tank Pegulrtaryan0Iysls Worksheet The regulatory requirements below ore determined hosed on requested emissions. • mmwm"plm1,.. ,,.....•.....:. an 2,6x Reaadmm.nx I A A,NMnmItrouee+ualemunonsscentallyolteno paAmmof7060lalnainaa wurce frees.nhan2mY.IReeu Iona.p.n a,xmm�ll.D.v.P n wa q .n Ap[x.0oman4 nenO2emm� • 1.Is the construmon 2 ana/2a.ana not moauled mar 4/1.414.M1 stor+mt+n.tmeuenput less than a0.eo0 gallons per year Ise.ps Memo..11maddhmnal[Meanie an grandfather appxmeretvi, No Go to neat quest. s.Ara to uncontrolled vac emislons greater than sips,.,greater than low,.coemhsmns treater than 10,1'IReOxxon3,pane,sect.rl.o.31x Ye, Source Requires a permit w d,eOlty II a N L1.Art uncontro.em n,pollutants trornthls.1nel...source ereaterah+nvrry Reav2'13 was smwn.0.t?Ix gran+s2 eaaa nerapp we NI) sofa a+ n0.n srpv orc0 em ssonseraaer<Nnlotpvalueu at ohs were ran on.D.xr [alp. on LC, 1.Is this nom.tank located In.S.Iir ozone.rontrol are•or any mane non.attaknment arear ant/maintenance area IRe[ulatron pan D.season l.A11) Storage ian.I,not subject to Regulation 7.Pan D.xnlon l.you nave imitated the me attainment gat.on the p.en summary sheet. Z.Ir ammo WIN located az all and 44,operatInns that collect.slam or handle hydrocarbonliquds or produma water AND that are located at or upnrnm of a natural gas processing plant lReeulmlon 7.Part D.section lAllx 3. gimp tank located eta natural{as .nine plant Megulatwn x.Pan D.sectjon l.alx storage,.Is no,subloct to Regulation),pan 0,xnla l.c•yon nave rnelateef...Ay type on project summary shoot, nslReu c21) •6.Are unconvolletl aaoal of this storage tank equal to or greater Man non,per Vea,V.Meio,allon,Part D....on o3.aJ I) NA • Pad 0,Sollon I.C.1—General Requirements for Alr Pollution control Equipment—Prevention of Leakage ones ereana Rep2 ere Pane,son. anti —.mast Repturernents for Alr Pollute!,Control Epulpment—PreuentIon of Lealgato irk nmNao 2,Is Ibis sloOle tank'located at an oil and B.explorallon and production operatton.well preeunlonenuty.natural gas compressornatnn'or natural as prxeeslneplant'IReeulauon).Part O.Seal=l.glx You have mdcated nnnry type far proles summary.get. a.area was asspnyearvOe lReeulamn).was 0.sevlon ll.v.qx vas xwa°wgea70pmsol Reeulalo'1>.p.nD.54mm�s n.ePc.cote tn4'1nteuestlo'1 to ran on<.2 en INa hour.1 +su4/500a promaona of xe[u2tmnx 560 O.54025 II.sebanons 3.c 6.wNt .tor.. aced lnneve ntm eP Y w,bo q p use watt/lReeulatlon).pm D,xnion lh<.AaUfx meXlee en or mgr May l.3o N° s70mee nn.lanet,ublen t2 Rqulvron 2.55 D.zemm�ll.c.a r T.z.zox Ina ted a wcIl prod.tIon lac..natural gai compressor stallon,or natural eat processing ern P Jm0eaual ehsougheuteg plant vbonl0tlon Dr aced 4,1,01 ,[44D.xmm�llt wawas mlxmAtl on or alter lamas xo n n 4wt1611 a®2 eer,j laocrR so.zvablall. �Y� x.Does the slur.vessel meet the following.exernotion Ialgx N„5 102. ml'10 eey used ed.processed.or treatedplar evtraneer as tlnt•nealn 6o.l11ey 3.Waal.norage vessel constructed.reconstructeCor misl ed elrnhmnsmerry6D.21 after July 23,1984 00 C.160.11rolal0, 5,Dees Oe 9orage vessel store evolatIle organic lkulltl lV0eas defined In 50.1110 •6.D°e wlzs pnf.n boo ,e 160 ablafmv NANA h.-F.0Op capacity gteater than r equal w13.1e[-SKIM]an n,6D.zmbib,,or NA c.nodes.,capacity',treater than or equal 10 m'1.01 SKI hatln,than 1526'VISD 6131,and stores a 110.1 with a maximum term vapor/.reason ler,man 15.0 kpa160.u0bmin NA • or.7551 to 74 NV 4472 BBL]but1..0.'1 1516 r95025/an sores a m a mailmum true vaporpreoure«5 5,4555 q .5 14 7015.0 bat.0..2y62pn/ NA • aacgR,panon,subwn0000/000.smnmre.of p.da.6.narorcwa.oa„a xxuwt0as pmaunmw)mmmu,lonana 0nxiwn°n 2.was this storage venal conrtruttetl,reconstructed,or .Isms dellnItIons 40 CFA.60.2,helween AtigUst 23,2011andpmmder 16.x015) +ao'1.'1a.tum¢e sspn4m amelnau try ubf< vs000D-Dace t440.t..t,on to mntlnoedetrmrn+xon at xsn 0002 pp eiuty.3,Was.110.storage vessel constructed.reconsmcted.or modIlla0 leee tlefinItinns 40 CFR,601,after o to the next questIon storage than ore n5 pervear) rla2olsl NO wage Tank knot wblen xspsa0am. lea 011 requ uments for storgeesuan w CFR Pan 60 Subpart or 40 CFI pan 63 Subpanxxx NA • • [NO.:11 a20r+g55 20,5v...ells pranoslyexermineda0 b:wye.to x5520000/0000aduememissions above.tons perys.rvoc on the appllabNgaetannIn+don date,It timidremainwbiettorasps 0000/Doom per 6000.545/.1/x1160.536x1.1121 own 5aam1a1v4e omissions drop 5ebw 6 tone pe,5,551 40CFR 74065 Subpart n In on,m Gs,production fao/r, 1.I5 We stomp lank locatod elan°an o2wm[wxma. P.. kanxnw•y°vhwe6matae cede°wee wteemyan the Prefeeuumm,w.neet. a.Afacmty bon prhydrocarbonre5,555,5des or notes hydrocarbon 11521E,m166)60IaII2fL DR b.A laellity that l .Maas prior to me point at which natural gat enters.natural gas trensmnslan and storage soma category°,is dellm m red a final end user I63.160lagllllx 2.Mlle tanic located at a facility.,Is lere'for NAP, sorapan,.yunot sublea MAn Nx mea+,e no Macrxx regmame'1umrmnx,aa,a,owa,3.Does the tank meet!.definillon 'In 63.761i NA e v wan me potanml for msh eml.aons.per 63.7611 S.Is 70 tank m 4 sub, control requirements Under .w 90CFR pan 6o. bpart Re or subpart 0000, NA.... sal+I T.b14z 463.gpsMasl70�lnvont al standards 462.»0-Remra.eepin[ 465.»5-Reponln[ RACTRavlow RAcimulw nquma pnoeulmlonx Jon hot apply Axanmetan.Isles raga nonwttaement awn.xtlwmnF mats eml:vRnea,trren mil..pats mquk.m.nu. Dladalmer nNiydcad;ferryfiremonls Clutin/WA,. ',Wm.'',rep.loos.and,OciedilyConfral Commission re4243.7.s.This document's not amber regal... alVeleb itcmeirm me Rot apply to document y 0054/4getyw�4grrouaemenl and a nal legally enraceabb In/buoyant o anyconlI behveenlnaknawaatnfa(locum'',anaJaln ana weaau cleanryaaact3:7N:,,pkrnarmaep non A40ueliy CmtolCwwNaxlm rwWeliwm ra lang4ege •arinesetute4„4gulethanw0 •mnwl.i mandelaylen endebyk,mindegy such ee'musr end>muired've IneJdedadescribecmbo5 re5ub udr:ee as mama/ clean Air AO and Air puely CControlCmiaali teguelb!Cuf Ufr's oacum.'[foss mleamdM1n legally eineng requremens in end itself COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name CCRP Operating Inc. County AIRS ID 123 History File Edit Date '>rstt(ii':i f Plant AIRS ID A070 Ozone Status Attainment Facility Name True Ranch Fee 2326H EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total • XA Two(2)0.75 MMBtu/hr Heaters 0.1 0.1 0.6 0.0 0.5 0.0 0.1 0.1 0.6 0.0 0.5 0.0 Insignificant Source XA Fugitives 0.1 0.0 0.1 0.0 Insignificant Source 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 • 0.0 0.0 FACILITY TOTAL 1.3 1.3 0.0 0.1 42.0 3,307.3 0.1 64.1 119.1 1.3 1.3 0.0 0.1 11.9 70.7 0.1 44.7 3.2 VOC: Syn Minor(PSD and OP) NOx:True Minor(PSD and OP) CO: True Minor(PSD and OP) HAPS: Syn Minor n-Hex&Total HH: Area source-no affected sources ZZZZ: Area source . Permitted Facility Total 1.3 1.3 0.0 0.1 41.3 3,307.2 0.0 63.6 119.0 1.3 1.3 0.0 0.1 11.3 70.7 0.0 44.2 3.1 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 1.3 1.3 0.0 0.1 11.3 70.7 0.0 44.2 Modeling not required based on A change in emissions.Pubcom is required b/c new syn minor limits are being established and the change in VOC emissions is greater than 50 tpy. Total VOC Facility Emissions(point and fugitive) 70.8 Facility is eligible for GP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) 70.7 Project VOC emissions greater than 50 tpy Note 1 Note 2 Page 1 oft Printed 6/1/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name CCRP Operating Inc. County AIRS ID 123 Plant AIRS ID A070 Facility Name True Ranch Fee 2326H Emissions-uncontrolled(lbs per year POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP'H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0770 Six(6)500 bbl fixed roof crude oil 4172 2971 848 1550 95058 52.3 storage vessels 002 19WE0771 Natural gas venting from two(2)three- 8177 9093 1481 3807 93680 58.1 phase separators 003 20WE0017 Four(4)500 bbl fixed roof produced 3,802 11,950 7.9 water storage vessels 004 20WE0018 Hydrocarbon liquid loadout 45 398 0.2 005 GP02 SI RICE PSI D111L,4SRB,268 HP,SN: 715.7 9"r 4 91.5 55 2 101118 0.5 EE1OH807545 XA Two(2)0.75 MMBtu/hr Heaters 2u 0.0 XA Fugitives 02 0.2 0.0 0.1 2 0.0 0.0 0.0 0.0 0.0 0.0 TOTALf(tpy) 0.4 0.0 0.0 8.1 6.0 1.2 2.7 100.6 0.1 0.0 0.0 0.0 119.1 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls(Ibs er year) POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE0770 Six(6)500 bbl fixed roof crude oil 84 60 17 31 1902 1.0 storage vessels 002 19WE0771 Natural gas venting from two(2)three- 164 182 30 77 1874 1.2 phase separators 003 20WE0017 Four(4)500 bbl fixed roof produced 191 598 0.4 water storage vessels 004 20WE0018 Hydrocarbon liquid loadout 3 20 0.0 005 GP02 SI RICE PSI D111L,4SRB,268 HP,SN: 715.7 974 9'1.83 55.2 105 8 0.5 EE1OH807545 XA Two(2)0.75 MMBtu/hr Heaters 20 0.0 XA Fugitives 0.2 0.2 0.0 0.1 2 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0,4 0.0 0.0 0.2 0.1 0.0 0.1 2.2 0.1 0.0 0.0 0.0 3.2 2 123A070 6/1/2020 Coloratie Air Perrnitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 9: 402646 Received Date: 7/19/2019 Updated application received 12/31/19 Review Start Date: 4/27/2020 _Original review started by J.Ricci on 10/14/19 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENE 23 12N 65 Plant AIRS ID: A070 Facility Name: True Ranch Fee 2326H 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 AIRS Point 9 Permit (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already 9 Required? Remarks assigned) assigned) Permit Initial 002 Separator Venting ECD 1&2 Yes 19WE0771 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc.is requesting permit coverage for several new sources at a synthetic minor oil and gas well production facility located in the ozone attainment area.With this application,the operator is requesting traditional permit coverage for crude oil storage vessels,natural gas venting from separation equipment,produced water storage vessels and hydrocarbon liquid loadout.The operator is also requesting GP02 coverage for one(1)SI RICE.This analysis only evaluates the natural gas venting source. This source is APEN required because uncontrolled requested V0C emissions are greater than 2 tpy(CO AQCC Regulation 3,Part A,Section II.B.3.a.). Additionally,the source is permit required because uncontrolled requested V0C emissions from all APEN required sources at the facility are greater than 5 tpy (CO AQCC Regulation 3,Part B,Section II.D.3.a.). Public comment is required for this source because new synthetic minor limits are being established and the change in VOC emissions is greater than 50 tpy. 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 Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O OOOOO Title V Operating Permits(OP) O OOOO ODE Non-Attainment New Source Review(NANSR) O ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O O O ❑ ❑ Title V Operating Permits(OP) OOOOO OOO Non-Attainment New Source Review(NANSR) O O Section 01-Administrative Information Lac ICy AIRs ID: 123 A070 ;002 County Plant Point Section 02-Equipment Description Details Dewed Em ssions Unit Description: Natural gas venting from two(2)three-phase separators. Two(2)Enclosed Combustors(Make:Crimson Energy,Model:CE-1000,SN:CE100D-CCRP 0318&CE1000-CCRP-0218) Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency%: 98 Limited Process Parameter .34-33244333234,434-33,3o3344.21331.l3 32A3434431323.3.3,,,24.43 Gas meter Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 75.5 MMscf per year Requested Permit Limit Throughput= 90.6 MMscf per year Requested Monthly Throughput= .-i MMscf per month Potential to Emit(PTE)Throughput= ::MMscf per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 1638.6 Btu/scf Volume of waste gas emitted per Bat of °ti _ '".-, liquidsthroughput: 1666141141,6„61.11j s crib bl Control Device Number of pilot lights 2 Pilot Fuel Use Rate: 22 scfh _-MMscf/yr Pilot Fuel Gas Heating Value: 1638.6 Btu/scf .J._3':,B MMBtu/year NEffigianitigg Section 04-Emissions Factors&Methodologies Description ' Two(2)wells produce to two(2)inlet three-phase separators at this facility.The natural gas vented from the three-phase separators is routed to and controlled by two(2)enclosed combustors.In order to develop site specific emission factors,the operator obtained a gas sample from the outlet of the two phase separators on 02/11/2019.The sample pressure is 99.57 psig.The molecular weight and weight%values from the sample were used in coc)unction with the Displacement Equation listed below to develop the site specific,ernission factors. MW I - 29.487 lh/Ib-mol Displacement Equation Heat Value Calculation Eeo0'MW'Xx/C Weight% 'O Helium 0.0000 3.401 CO2 5.0760 0.923 N2 0.8770 :.- 57.846 -. methane 31.4730 30.993 ethane 11.2100 propane 19.9910 1.649 isobutane 3.2500 n-butane .11.4660 isopentane 3.6310 - - 1:643 n-Pentane 4.0290 0 cyclopentene 0.0000 n-Hexane 1.3290 cyclohexane .0.3870 Other hexanes 2.1350 "0 - heptanes 3:0540 0.385 methylcyclohexane 0.0000 .. 0.074 224-TMP 0.0000 Benzene 0.1160 Toluene 0.1290 Ethylbenzene 3.0210 - 0.005 Xylenes 0.0540 Octanes 1.3806 - OA54 Nananes 0.2980 - 0 C10+Heavies 0.1030 Total .. VOC Wt% o.,_ uE of va» 1.34122.407=3.433" o.3.2434—06:Ing flue of Gos 14334 98324 bts.., 2 of 5 -C:\Users\hslaught\Desktop\123A070\I9WE0771.CP1 Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ib/MMscf) (Ib/MMscf) (Gas Throughput) (Gas Throughput) VOC 232_' _ _ dedgasan5fyss Benzene Toluene _" 122'224,124044.1(#45A•• ..: Ethylbenzene :_ ... Xylene n-Hexanee.e I.' pf arr<lggq 224 TMP _. tendetlgasarral'; Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 =„0.0075 42Table 1.4-2(PM10/PM25) PM2.5 �0.0075 'F ble 1.4-2(PM1011'M 2.5) SOx 0.0006 ._ Y-Ap-42 Table L4-2.(SOS) NOx 0.0680 __,..« AP-42 Chapter 13.5 Industrial Flares(NOx): CO 0.3100 ...v:e60 AP-42 Chapter 13.5 Industrial Flares(CO).. Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0.0075 12109? .ab28 4.-. At,2,. a,. PM2.5 0.0075 .2.22.22s SOx 0.0006 6 NOx .0.0680 1.7_a3 VOC 0.0054 ,. _ - CO 0.3100 _lice -, . tad.1, flares` Ofrz 9 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) (tens/year) (tons/year) (tons/year) (lhs/month( PM10 ___ M.__ 2„a.. _-- -,4 PM2.5 2._ SOx - _. _-- VOC l<322.>,.. V..53 .... . CO 22_,._ ...«_ Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year( (Ibs/year) (Ibs/year) (Ibs/year) Benzene Ke.. ; ..__ __.. ___ Toluene .,,32 Ethylbenzene 1122 22 12.2s 22 __- Xylene ;"s_,,..._ .s?t 5, _ n-Hex 2.-., .. ... 224 TMP Sc._, ,.r. ;._ Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B ,.., :_2. .- Regulation 7,Part 0,Section 11.0,F Regulation 7,Part I,Section 11.6.2.0 (See regulatory applicability worksheet for detailed analysis) 3 of C:\Users\hslaught\Desktop\123A070\19WE0771.CP1 Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? Yes This sample should represent the gas outlet of the equipment covered under this AIRS ID,and should have been collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use en older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 40 tons per yearn the ozone nonattainment area OR are emissions greater than or equal to 90 tans per year in the ozone attainment area? If yes,the permit will contain: -An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter Installed and operational upon startup of this point? If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter Is Installed and operational net to exceed 180 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value In section 03. • Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Eta fiZTLIEMBETZUMEir:aitiNFZEZZiatilail=iliEallagigaarigi2-1422XEMEAVIONEORNEaujillineiglEMINfil _ , t`b'<-'�3bi . ..'r=vbii k�l+' ,..., m "E�- F F.-5,kia.<v'S,o-.. �47'..d-r1 ,smr,_rMrr..v.._cvo,ne. <. a „vr,r,esnrgereetle=mrs Section Ut-Technical Analysis Notes 1.According to the APEN,two wells produce to thlsfacility.The names and API numbers of the wells Is as follows:(I)Name:True Ranch Fee 202-2326H,API Number:05-123-47411;0j Name:True Ranch Fee 502-23268,API Number.05-123-47413.According to COGCC data,the True Ranh Fee 202-23268 well basses begun production.The True Ranch Fee 502-232611 well was fractured In December 2018 and began production In January 2019.Since the wells began production after 08/01/2014.the separators covered by this point are subject to Regulation 7,Part D,Section II.F. 2.According to email documentation from the previous engineer,the sample used to establish emission factors in this application was obtained from a temporary separator during the flowback period.As a result,the Initial sample may not be representative of actual emissions from this source.Based an this information,the permit will contain an initial sampling condition.This sampling requirement will require the operator obtain a site specific gas sample and use into develop site specific emission factors.These newly developed emission factors will be compared to the emission factors established through this analysis.If any of the new emission factors are greater than the original values,the operator will be required to submit a permit modification to use the new more conservative factors. 3.Since the operator Is requesting greater than 95%control for this source,the operator is required to conduct annual gassam piing. 4.The operator has requested a 98%control efficiency for the two enclosed combustors used to control emissions from this source.It should be noted that the enclosed combustors are used to control emissions fmm the crude all storage vessels,produced water storage vessels and hydrocarbon loadout sources as well.However,the operator has only requested a 98%control efficiency for the separators and crude oil storage vessels.This simplifies the initial and ongoing compliance test since the number of scenarios that need to be tested is reduced.The operator is still required to conduct a test that encompasses.each normal operating scenario In order to demonstrate compliance with the emission limits for each shame requesting 98%control and demonstrate the source is capable of meeting the requested destruction efficiency at all times.The permit condition will be structured in a manner to account for these scenarios.It should be noted that the operator indicated thatthey are capable of isolating the separator gas from the crude ail storage vessel gas.This capability will allow the operator to differentiate the emissions associated with the crude oil storage vessels from those associated with the separators.The stack testing protocol should take advantage of this capability in order to demonstrate compliance with the individual emission limits for each source and to demonstrate 98%destruction efficiency during each normal operating scenario. 5.5ince the enclosed combustors are used to control multiple sources at this fatlfity including the separators(i.e.crude oil storage vessels,produced water storage vessels,and loadout),the pilot light emissions are grouped with the highest emitting source that Is controlled by the common control device.In this case,the three-phase separators are the highest emitting source.Therefore pilot light emissions are evaluated in this analysis.Additionally,the permit will contain a limo on the volume of pilot light gas combusted along with emission factors In the notes to permit holder.These additional limits and emssion factors must be accounted for because they differ from the methods used to calculate emissions from the separator venting source. 6.Engineering guidance dictates that combustion emissions from all sources controlled by a common control device should be grouped together for evaluation against APEN thresholds.In this case,NO0 and CO emissions from all sources controlled by the enclosed combustors are above APEN reporting thresholds.As a result,the permits for three-phase separator venting,crude oil storage vessels,produced water storage vessels and hydrocarbon loadout will all contain emission limits and emission factors for NO%and CO. 7.Amending to the application,a flow meter is installed and operational at this fawlrty.This flow meter only measures the three-phase separator gas routed to the enclosed combustors.The operator also Indicated that there is a flow meter in fine with each combustor.As a result,the operator will be able to accurately track the volume of gas sent to each combustor during pilot light outage and assess the total emissions that were not controlled. 8.There are no vapor recovery units(VRUs)on location for the three-phase separator gas.Asa result,the operator has indicated the produced gas from the three-phase separators is always routed to the enclosed combustors. 9.The heat content used to calculate NOx and CO emissions was taken directly from thesample analysis.The heat content calculation in this analysis demonstrates the methodology used to estimate heat content of the sample.While the calculations in this analysis do not math exactly with the value presented on the sample report,the difference is small enough to be considered negligible. 10.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.As a result,the permit does not contain Initial or periodic opacity testing. 11.The operator was provided with a draft permit and APEN redline to review prior to public comment.The operator reviewed both documents and expressed they had na comments. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) AIRS Point d Process g SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 002 01 PM10 .... PM2.5 SO% N0x VOC CO i...._ .. Benzene „_. -.. Toluene Ethylbenzene XYlene n-Hexane i-- 224 TMP 4 of 5 C:\Users\hslaught\Desktop\123A070\19WE0771.CP1 • Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado 3 Parts A and B-APEN and Permit Requirements • ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants front this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? Yes .:I Source Requires an APEN.Go to the next question 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section II.D.3)? Yes .Source Requires a permit Hurt,teem is a parrs, NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section IIA.l.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section II.D.2)? Colorado Regulation 7,Part D Section II 1. Was the well newly constructed,hydraulically fractured,or ompleted on or after August 1,2014? [Yes (Source is subject,go to next question Section 11.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities • Alternative Ernissions Control(Optional S tion). a. Is this eparato tolled by a back-up or alftrnate combustion device(i.e.,not the primary control device)that is not enclosed? INo 'ilThe control device for this separator is not subject to Regulation 7,Section XVII.B.2.e Section II.B.2.0—Alternative emissions control equipment Disclaimer • This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is 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. PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package#: 423850 Received Date: 12/31/2019 Review Start Date: 4/28/2020 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENE 23 12N 65 Plant AIRS ID: A070 Facility Name: True Ranch Fee 2326H 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 AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 003 Produced Water Tank PWTANKS Yes 20WE0017 1 Yes Issuance Section 03-Description of Project • CCRP Operating Inc.is requesting permit coverage for several new sources at a synthetic minor oil and gas well production facility located in the ozone attainment area.With this application,the operator is requesting traditional permit coverage for crude oil storage vessels,natural gas venting from separation equipment,produced water storage vessels and hydrocarbon liquid loadout.The operator is also requesting GP02 coverage for one(1)SI RICE.This analysis only evaluates the produced water storage vessels. This source is APEN required because uncontrolled requested VOC emissions are greater than 2 tpy(CO AQCC Regulation 3,Part A,Section 11.8.3.a.).Additionally, the source is permit required because uncontrolled requested VOC emissions from all APEN required sources at the facility are greater than 5 tpy(CO AQCC Regulation 3,Part B,Section II.D.3.a.). Public comment is required for this source because new synthetic minor limits are being established and the change in VOC emissions is greater than 50 tpy. 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 Requiremen Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ E ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ 1 ❑ DOE Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 0 0 0 0 0 0 Title V Operating Permits(OP) 0 0 0 0 0 0 ❑ 0 Non-Attainment New Source Review(NANSR) 0 0 Section 01-Administrative Information (Facility AIRs ID: 123 AD70 003 County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Produced Water Detailed Emissions Unit Four(4)500 barrel fixed roof produced water storage vessels connected via liquid manifold. Description: Emission Control Device Enclosed Combustor(s) Description: Requested Overall V0C&HAP Control Efficiency%: 95.0 Limited Process Parameter tigidTpt' Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= 452,629.0 Barrels(bbl)per year 'Requested Permit Limit Throughput= 543,154.0 Barrels(hbl)per year Requested Monthly Throughput= 4i:1!^.'3 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= 543,154.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 1496.0 Btu/scf Volume of waste gas emitted per BBL of liquids produced= 36.0 scf/bbl Actual heat content of waste gas routed to combustion device= .':I.:"_.e MMBTU per year Requested heat content of waste gas routed to combustion device= a,:+__.'MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= MMBTU per year Control Device Pilot Fuel Use Rate: scfh :1 3 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 0 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? c-- Emission Factors Produced Water Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water (Produced Water Throughput) Throughput) PrddU cd Water State E.F..(Includes flash).Front V0C 0.2620 Range&Other Produced Water State E.F.(Includes flash)-Front Benzene 7.00E-03 Range&Other Toluene Ethylbenzene Xylene Produced Water State E.F.(includes flash).-Front n-Hexane 2.20E-02 Range&Other 224 TMP Control Device Uncontrolled Uncontrolled Pollutant )lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Produced Water combusted) Throughput) P5110 0.0075 AP-42 Table 1,4-2(PM10/PM.2.5) PM2.5 0.0075 - AP-42 Table.1.4-2(PM10/PM.2.5) S0x 0.0006 AP-42 Table 1.4-2(50x) 500 0.0680 AP-42 Chapter 13.5 Industrial Flares(flax) CO 0.3100 - AP-42 Chapter 13.5 Industrial Flares(CO) Pilot Ught Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 PM2.5 SOz _ NOz V0C CO Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Umits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Has/month) PM10 .. ...... _-` PM2.5 _ 551 ' 500 NOz VOC -10.53 i9.2!1.l CO 4w 3_f tU 3.7" 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 2.3 3165;c - Toluene Ethylbenzene ?n Xylene n-Hex t .J O_S'34 224 TMP -G('`u 50 _ 0.00 2 of 4 C:\Users\hslaught\Desktop\123A070\20WE0017.CP1 • Section 06-Regulatory Summary Analysis Regulation 3,Parts A,8 ... ..�,..... Regulation 7,Part D,Sectlon I.C,D,E F Regulation 7,Part D,5ectionl,G,C .-' .S•rtic:i-: Regulation 7,Part D,Section ll.B,C.1,C,3 _ Ode'I)sec .... Regulation 7,Part D,Sectlon Regulation 7,Part D,5ection II,C.4.a.(i) Regulation 7,Part O,Section Regulation 6,Part A,NSPS Subpart Kb • - - Regulation 6,Part A,NSPS Subpart 0000 NSPS Subpart 0000a ...:.. •.. Regulation B,Part E,MACF Subpart HH (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to estimate emissions? i" If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than qual t 20 tons VOC per year OR are the controlled actual or requested emissions fora condensate storage tank estimated to be greater than or equal to 80 tpy7 +�?,q.dr N/A-this source consists of produced water storage vessels If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines In PS Memo 14-03. Does the company usea site specific emissions factor to estimate emissions? kes'A_e• If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being M1 permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample should be considered representativewhich 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 sample. on-One),then it may be appropriate to use an o Y older site-specific It"' N/A-the operator used the state default emission factors to calculate emissions. p 3\su If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? 141414 If yes,the permit will contain initial and periodic compliance testing In accordance with PS Memo 20-02 Section 08-Technical Analysis Notes 1.According to the application,two wells produce to this facility.The well names and API numbers are es fellows,( Name,True Ranch Fee 202-2326H,API Number:05.123-47411;(0)Name:True Ranch Fee 502- 2326H,API Number:05-123-47413-According to COGCC data,the True Ranch Fee 202-2326H well has not begun production.The True Ranch Fee 502-23268 Well was fractured in December 2016 and began production in January 2019.The well that is currently In operation produces from the Codell formation. 2,The produced water storage vessels,hydrocarbon loadout,separator venting and crude oil storage vessels are controlled by the same enclosed combustors at this facility.As a retch,the pilot light emissions are not calculated in this workbook because they are evaluated with the separator venting source(18WE0771).Engineering guidance dictates that plot light emissions should be grouped with the highest emitting source.when sources are controlled by a common control device.In this case,the highest emitting source is the natural gas venting from the three-phase separators.. 3.Even though NOx emissions from this source specifically are below APEN reporting thresholds,the total NOx emissions from all sources controlled by the enclosed combustors(produced.water storage vessels, crude oil storage vessels,separator venting and hydrocarbon loadout)are greater than APEN thresholds.As a result,the permit for each source controlled by the common control device will include limits on NOx emissions.TheCO emotions resulting from combustion of produced water storage vessel waste gas Is above APEN thresholds without the need for comparison to other sources. 4.Initial and periodic visible emissions checks for the control device are addressed 6ythe O&M plan.Asa retch,the permit does not contain Initial or periodic opacity testing, 5.The operator was provided with a draft permit and APEN redline to review prior to public comment.The operator reviewed both documents and expressed they had no comments Section 09-SCC Coding end Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point Process k SCC Code Pollutant Factor Control%Units ,_. 01 4-04-003-15 Fixed Roof Tank,Produced Water,wakingoNnwsghingfflashing(usses;,,, PM10 ..._ _ b/1,000 gallons Produced Water throtighput PM2.5 .._.. _ b/1,000 gallons Produced Water throughput SOx :.-.:- 6/1,000 gallons Produced Water throughput • NOx - 6/1,000 gallons Produced Water throughput VOC .....- 6/1,000 gallons Produced Water throughput • CO :.-1 - 6/1,000 gallons Produced Water throughput Benzene _._. b/1,000 gallons Produced Water throughput Toluene :_ b/1,000'gallons Produced Water throughput Ethylbenzene ,_ 6/1,000 gallons Produced Water throughput Xylene b/1,000 gallons Produced Water throughput n-Hexane b/1,000 gallons Produced Water throughput 224 TMP I,.Vf b/1,OW gallons Produced Water throughput • 3 of C:\Users\hslaught\Desktop\123A070\20WEW17.CP1 Storage Tank Regulatory Analysts worksheet The regulotoryrequirements below ore determined bused on requested emissions. pi]aINM9n1. 3 ar.unaomro ea anus.masvn.nomanyaerapo utamsnomtns neveu,morn¢r nzipv l9ttu at ens wnasan on o.3+17 VnSource Requires an aPEx Go to tile not question 3.Are total uncontrolled emissions seater than 57PV,NOx greater than 10171 or GO...Mons greater thanl0in Negubtmn 3.Part B.Seaton.o.31i ya..oF^svurm aeq.raap.rmrt NON-ATTAINMENT 2.Produced Waterfall.have no grandlatherIng provisions 3.Are total latillty nag nr greater than 2 TPV.N,,,x Iv eater than V,,or CO emissions gre er than 1017,IPteulation3,Part S.Seaton 11.0.117 I,IsthiPnrage tat],Part L,moonbetao nt/duced ann AND that.lon].Pano,eatenmofa rn.r.n4lan.t,nwntto P<gq.n.n].Pan o.smm�_voa nave Inalntnm<n[<attain.<nt a.tuaon to<prol.a,umma,Y,nnt. 2.Is 11..0.tank located at and gas°per...that n Samoa hydrocarbon rilpu�a or produced water AND that+r<Inatea nor upnr<om oianaurngas processing plant r9ttulaton J.Part O.Section l.alti m a.Is gouge rank located at a natural ssin[vont(Regulation J.Parto,senlon soli 5mraeerank is net subjecttv Regulation J.Part O.Saolon l.G•You have lnelntetl fnllayap n pralea summary sheet. 5.Does thls storage sr,.e.stonn¢nomstoblurcellquMsl a.ladonslPezulahon 7.pan0.s<nlvn kG.zli 6.Are uncontrolled actual ernIssionsol this storage.tank equal to or greaser than 2 tons per year Ot pegulation]Fartp Sectors.o.3at 117. Pa. Mon,toNnt Part 0,Section I.C.1.aana h Requirements for Alr PollutIon Control Equipment—Prevention of Leakage folorado Pe.ulatlonJ Part O.Seaton g 1.Is this storageon/sto ,, u n ave r ma 2. thla storage lanV lo.t.a at an oll and gas exploration and production opemlon,well product,.raollitY.natural gas compressor station,' proc.Vog plant.(Regulation 7.Part 0,Section 3. his storage ta.have a Ned roof illegulation 7.Part 0.5ectIon a.crest ee esugee to partsar Pegu at en J,Part o,sen nn,.eac.rmmmenvt vuea en r sea on e.x.bl] Ix`' So rn a subject to all prove one of Regulation]Part o,xenon Subsections BS.C Part 0,Sactlon 11.0.2.Capture and MankorIng for Sto.age Tanks..witM1.11,Pollution Control Equipment 6.sumt na a .a mra samthmttn pn Inp murbn^ quq p dunawata Pee.nan J,Wn P.saaon cA.,IR mtldeaonor,nerM Ne.ti•+'�stoageian41s not.Meet to Regulation r,Pan o,sealonll.e.9 1.Isl....Wel storage vers<1 capacity,greater than orJ.1.x0x r, a .e a paled naeam nthrvue v o varamreon vu eaorproaune weer rP<eu at on J.wrt 0.sm on.c.9.a,rmlitll eon or.Neenua xv. I a<thu n v t ke:t< star as eve an ante np t 1st nenlmll a]]99u1 1a0 cFP 60.110n1a117 z.ion vn toratt]nkls not r.Nen NSPsxh. 1101566.9]4 m'1-ie.em 99t1.seafor pnrvle.m or<ondnssenmed.pmaed.arerned ones to aaedYtnnski'aseAmedm6e,1r16i NA a nlnlmns 9ocFa6o.zlan=r solo Js.3dao la0cra6o vgbl,ll3 n mee Ile taro b] 6.Dees NA a.Is tne storage < s w1-96.J psi an tn. ns mssioo a re 160 13.1-ne Jove,capacity Is greater'than or .[1-030 FM,aita stores 11,..14 wall madroum true vapor pressure'less than 3.SMPa MO.11013011,yr c. eaoadly Is great., o. n41,02 gN b. .'1'950 aetl and store,a liquidwltha maximumtru . pass,.less than 15..0 kPa160.11nhp,,, NA 7.Does the storage ta.meet either anent the ollowirtg exempt.. 9sae9tl control an arequirements: a a ua v a Sea NA earl eu ge tams Na a0 aR P,ng0,s.hwn 0000/0000.,ManmNsol P.nownannlaemaeoll.na Natural casPmauamn,Tnnsmisrion naoisxitildon 1.Is Ihis storage vessel located al the onshore ell and natural gai.protlualon segment,natural gm proce.Ing segment or natural Os soon and storage eegment of the InduetM Pralea summary snen. .d la« pre bole.xognNO Storage Tar. f.ubjestsus 0000 Go m the Ile.[M.to.^ntln.det=rminatl^n of xsn 0000a app y 3.Was this storage vessel conslructetl,,reconstructe0.or ee Itndalln6lons ancFP.60.z1 alter xptembel le,20157 oat snags. ^P<yNo ...Stooge,.Isom. I NSP5000w. NA leery wit g mataroraor.ge.n,eannEFPP.n 6o5.bnaxbord9gFPpan63 p xx7 Na INm ..spoon tu oo/Oo o.misswmabosestom pryeal VOC on to.apginbnnya.t=.minboneat.,nmwo remainwbl.ato Seeps 0000/0000,p.r 60s3gsle1111/g0.s3ssalel161 even n potential weemasona m deep beowGmns per oe'Iau. 40 OK PiFt 63,Subpart MALT NH,Oland GAS PnadurCon Runt. 1.Is the storage tank located at an oil ar.0 natural gas production facility Mat meta caber WOE ollowIng eta. I„. INontlnu.•Vouha.=InalaI the source<tg v on the Pmlet summary sheet, a6located ata .mlga,pnormtn=polnaawn.n natural ea,.nnrt me ntnml gat,vanwma,tun ane,mregem..a negorYo.I,a=unneto annal ena.nr 163.76 al3tti 2.Is the tank major'for HAP, XONV StOri(e stns Isram whim MAR Sex]Wheat.no Man.requIrementsmr tanks at area sources xta>• . I,.n xb o,5nbpart nnoo. RNs. x63 IIACT Iw.view,.wum 5 R.,.Luon,aaanat.Ppxaxmrm.enku In n.nan�remmem ana.gm.nngmn.boon<aem,m.n r..I.wRaci mmrlrem.ne. This dauramaurae operators wlmrreNI,mnIOO.ppd<.bw&(0OMrinm oreineNA alma Clean kr Act.rimpatmn+Ilno.mmnnmr>end arweld0Con.Comr I,amnreaulalbn,.r pwr m O4-any olher Itinlndmlre00a'rernenta alu not yanlormwpk ihmeahnIola '�dtnNMµ�I11aIMN6 waaalms a nI®ON;�e a ON111,1not ca�n ilk AN A:°s�wwau.; veliy Cmbaleommisaim I...cos,Ill.language I Me.laluteor repute!.%vac...The use of neri-rneridailory language such as 1reoommend—may.—should•and ten.,intended lo deaorib O inlevpret vrbe.mbodrrg repuNevlenm under me term.wine Olean.1-Acton Ounry Cordrol Commission �m mis dowmnl does not establish bi chop rewremeen�7 am'Mendel Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package 9: 423850 Received Date: 12/31/2019 Review Start Date: 4/28/2020 Section 01-Facility Information Company Name: CCRP Operating Inc. Quadrant Section Township Range County AIRS ID: 123 NENE ` _23 '.12N 65 Plant AIRS ID: A070 Facility Name: True Ranch Fee 2326H 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 AIRS Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 004 Liquid Loading LOAD1 Yes 20WE0018 1 Yes Issuance Section 03-Description of Project CCRP Operating Inc.is requesting permit coverage for several new sources at a synthetic minor oil and gas well production facility located in the ozone attainment area.With this application,the operator is requesting traditional permit coverage for crude oil storage vessels,natural gas venting from separation equipment,produced water storage vessels and hydrocarbon liquid'loadout.The operator is also requesting GP02 coverage for one(1)SI RICE.This analysis only evaluates the hydrocarbon loadout source This source is APEN required because uncontrolled requested VOC emissions are greater than 2 tpy(CO AQCC Regulation 3,Part A,Section II.B.3-a.). Additionally,_the source is permit required because uncontrolled requested VOC emissions from all APEN required sources at the facility are greater than 5 tpy (CO AQCC Regulation 3,Part B,Section II.0 3.a.). Public comment is required for this source because new synthetic minor limits are being established and the change in VOC emissions is greater than 50 tpy. 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 Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) El O O O O O Title V Operating Permits(DP) ❑ ❑ ❑ O O O O O Non-Attainment New Source Review(NANSR) ❑ ❑ Is this stationary source a major source? No If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O ❑ ❑ O O Title V Operating Permits(OP) O O O O - O O O O Non-Attainment New Source Review(NANSR) ❑ ❑ Section 01-Administrative Information (Facility 123 A070 004 AIRS ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Hydrocarbon liquid Ioadout from storage to tank trucks using submerged fill. Description: y g Emission Control Device Vapor Balance and Enclosed Combustor(s) Description: Is this Ioadout controlled? , Requested Overall VOC&HAP Control Efficiency%: 95 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= 267,062 Barrels(kb))per year (Requested Permit Limit Throughput= 246,475 Barrels(bbl)per year Requested Monthly Throughput= _-..1 Barrels(bbl)per month Potential to Emit(PIE)Volume Loaded= 248,475 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2507.13 Btu/scf Actual Volume of waste gas emitted per year= -.-.- scf/year Requested Volume of waste gas emitted per year= .. , scf/year 1.053837192 Actual heat content of waste gas routed to combustion device- .. MMBTU per year Requested heat content of waste gas routed to combustion device= MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= MMBTU per year Control Device Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Fleeting Value: -Btu/scf MMBTU/yr Section 04-Emissions Factors&Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? =-1"2'.!:A?it?.41,S3 Emission Factors Hydrocarbon Loadout Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VDC __C-C , Crude Oil Loadout State E.F. Benzene 3 .- Crude Oil Loadout State EF. Toluene ,._ ... ... Ethylbenzene Xylene n-Hexane -..____ c _. Crude Oil Loadout State E.F. 224TMP _ Cl ._ Control Device Pollutant Uncontrolled Uncontrolled Emission Factor Source (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 :..+114- AP-42 Table 1.4-2(PM10/PM.2.5) PM2.5 0.0075 AP-42 Table 1.4-2(PM30/PM.2.5) 50x 0.0006 .., AP-42 Table 1.4-2(50x) NOx 0.0680 2.4_=1.. AP-42 Chapter 13.5 Industrial Flares(NOM) CO 0.3100 ..2)E C- 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) PM10 PM2.5 50x NOx VOC CO 2 of 4 C:\Users\hslaught\Desktop\123A070\20WE0018.CP1 • Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tans/year) (tons/year) (tons/year) (tans/year) (tons/year) (lbs/month) PM10 -PM2.5 500 NOx ..... a' VOC _ CO .....-. ._ .. -. Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) Ohs/year) (lbs/year) ]Ibs/year) Benzene Toluene .. _ Ethylbenzene Xylene _.i. __-_ n-Hexane 224TMP Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7 Part D Section II.C.5. --... (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes 1.According to the application,two wells produce to this facility.The well names and API numbers are as follows:(i)Name:True Ranch Fee 202-23260,API Number:05-123-47411;5-12 3-47411,(ii)Name:True Ranch Fee 502-2326H,API Number.05-123-47413. Accordingto COGCC data,the True Ranch Fee 202-23260 well has not begun production.The True Ranch Fee 502-2326H well was fractured in December 2018 and began production in January 2019.The well that is currently in operation produces from the Codell formation.The COGCC data indicates the API gravity of the fluid produced at this facility is below 40.Asa result,the classification of the fluid as crude oil is appropriate. 2.Benzene emissions are below APEN reporting thresholds(i.e.<250 lb/year).As a result,an emission factor will not be included in the permit for this pollutant. 3.The produced water storage vessels,hydrocarbon loadout,separator venting and crude oil storage vessels are controlled by the same enclosed combustors at this facility.As a result,the pilot light emissions are not calculated in this workbook because they are evaluated with the separator venting source(19WE0771).Engineering guidance dictates that pilot light emissions should be grouped with the highest emitting source when sources are controlled by a common control device.In this case,the highest emitting source is the natural gas venting from the three-phase separators. - - - 4.Evert though NOx and CO emissions from this source specifically are below APEN reporting thresholds,the total NOx and CO emissions from all sources controlled by the enclosed combustors(produced water storage vessels,crude oil storage vessels, separator venting and hydrocarbon loadout)are greater than APEN thresholds As a result,the permit for each source controlled by the common control device will include limits on NOx and CO emissions. S.The heat input rate of loadout waste gas routed to the ECD was calculated using the following equation:MMBtu/year=(Uncontrolled VOC(ton/year)]'[2000 lb/ton]/[Molecular Weight(lb/Ib-mol)]'(379 scf/lh-mol]/[VOC wt%in Flash Gas]•[Heat Content(Btu/scf)]/[1,000,000 Btu/MMBtu).The molecular weight,VOC weight%and heat content used in this equation were obtained from the flash gas emission stream as estimated by the ProMax simulation used to estimate crude oil storage vessel emissions at this facility.The specific values for molecular weight,VOC weight%and heat content are 44.9628 Ib/Ib-mol,83.1651261%and 2,507.13 Btu/scf respectively.When the state emission factors are used to estimate emissions,a molecular weight of 50 lb/lb-mol and heat content of 3,535 Btu/scf are typically used in this equation to estimate the heat-input rate.In this instance,the values used by the operator result in slightly lesssonservative emissions but are acceptable because they are based on site specific data. - - 6.Initial and periodic visible emissions checks for the control device are addressed by the O&M plan.Asa result,the permit does not contain initial or periodic opacity testing. 7.The operator was provided with a draft permit and APEN redline to review prior to public comment The operator reviewed both documents and expressed they had no comments. Section 09-SCC Coding and Emissions Factors'For Inventory Use Only) Uncontrolled Emissions AIRS Point R Process If SCC Code Pollutant Factor Control% Units 004 Ol PM10 ' lb/1,000 gallons transferred PM2.5 _ lb/1,000 gallons transferred 50x .._ _ Ib/1,000 gallons transferred NOx lb/1,000 gallons transferred VOC ... lb/1,000 gallons transferred CO -. lb/1,000 gallons transferred Benzene .. lb/1,000 gallons transferred Toluene ... . lb/1,000 gallons transferred Ethylbenzene - lb/1,000 gallons transferred Xylene Ib/1,000 gallons transferred n-Hexane -..._,. - lb/1,000 gallons transferred 224TMP ., lb/1,000 gallons transferred 3 of 4 C:\Users\hslaught\Desktop\123A070\20 W E0018.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section ILD.1.a)? • Yes Go to next question. 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section 11.O.1.1)7 Yes Go to the next question 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 question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? No Go to next question S. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? No Go to next question 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 II.D.3)? Yes The loadout requires a permit Source requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1)? 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 from the greaterthan 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section Il.D.2)? Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant? Yes. Go to next question. 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? Source is subject to Regulation 7 Part D Section II.C.5. Section II.C.S.a.(i)-Compliance Schedule Section II.C.5.a.(ii)-Operation without Venting Section II.C.5.a.(iii)-Loadout Equipment Operation and Maintenance Section II.C.5.a.(iv)-Loadout observations and Operator Training Section II.C.5.a.(v)-Records Section II.C.5.a.(vi)-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts 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. 0��3\1©19 �,�,, Crude Oil Storage Tank(s) APEN „ �` ' Form • APCD-210 .. CDVHE Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source(e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading,etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of 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: 19WE0770 AIRS ID Number: 123 /AQ70/001 Section 1 -Administrative Information Company Name': CCRP Operating Inc Site Name: True Ranch Fee 2326H Site Location Site Location: NENE Sec. 23 T12N R65W County: Weld NAICS or SIC Code: 211111 Mailing Address: c(Include zip code) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720) 961-9100 E-Mail Address2: imyers@clearcreekrp.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.My 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. 423946 MSC COLO•A.O 1 a.r.�•r�+w—. Permit Number: 19WE0770 MRS ID Number: 123 /A070/001 Section 2 - Requested Action 0 NEW permit OR newly-reported emission source O Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 O Other(describe below) -OR- I ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Storage of crude oil on site prior to truck loadout. Company equipment Identification No. (optional): TK 1-6 For existing sources, operation began on: 4/25/2019 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&Production(E&P)site ❑ 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 O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) 805 series rules?If so, submit Form APCD-105. ❑ Yes No Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual emissions z 6 ton/yr(per storage tank)? 0 Yes ❑ No RcitiMc.S P� ap,?i.catta01/4 t+ ?`� UT{1 ,peat J Permit Number: 19WE0770 AIRS ID Number: 123 /A070/001 Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbi/year) (bbd/year) Crude Oil Throughput: 207,062 248,475 From what year is the actual annual amount? Projected Average API gravity of sales oil: 35.5 degrees RVP of sales oil: 5.25 Tank design: D Fixed roof O 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 (bbi) Storage Tank(month/year) (month/year) TK 1-6 6 3,000 0412019 04/2019 Wells Serviced by this Storage Tank or Tank Battery('(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 47411 True Ranch Fee 202-2326H 05 - 123 - 47413 True Ranch Fee 502-2326H O O s Requested values will become permit limitations or wilt be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all welts that are serviced by the equipment reported on this APEN form. Section 5 -Geographical/Stack Information Geographical Coordinates (Latitude/Longitude orUUTM) 40.998623/-104.535017 Q 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) (IF) (ACFM) (ft/sec) Indicate the direction of the stack outlet: (check one) [�Upward O Downward O Upward with obstructing raincap o Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) ❑Circular Interior stack diameter(inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): lacCOlOR•00 Permit Number: 19WE0770 MRS ID Number: 123 /A070/001 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: VOCs and HAPs Rating: 42.5 MMBtu/hr Type: Enclosed Combustor Make/Model: Crimson Energy-CE-1000 o Combustion Requested Control Efficiency: 98 % -o".taR Device: C.104))-7) t a kg Manufacturer Guaranteed Control Efficiency: 98 � Minimum Temperature: Waste Gas Heat Content: t, =,3 ,, Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: r3 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)? —30 Psig Describe the separation process between the well and the storage tanks: 3-phase separators separate the fluid and natural gas. iktAx,v1/4.4— A)otsacck 0 0, t loA 54oL0 COLOIADO �,_ .. �r O*rwrt�rr, :j" t it x fir.ri "fa t=��tPS 4 Permit Number: 19WE0770 AIRS ID Number: 123 /A070/001 Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes O No If yes,describe the control equipment AND state the collection and control efficiencies(report the overall, or combined, values if multiple emission control methods were identified in Section 6): . Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) • emissions) VOC ECD 100 1$ NOx CO HAPs ECD 100 98 Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Emission Factor? Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 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 t1!'7'5 rouea SSEF %%1S$ t9.St- l'-w.gS itS.tt_ NO„ 0.068 lb/MMBtu AP-42 t D3 7-.01 j,.Nt-1 t 4t( CO 0.31 Ib/MMBtu AP-42 ot.Zt.o 41.Ito 11.1.. ti.tl_ s Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 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. e Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria 0 Yes O No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Number Basis Units Mfg., Emissions Emissionsa _ etc.) (lbs/year) (lbs/year) Benzene 71432 lvbxto; IbWbbi SSEF 3'-AW.,-• V1.5 Toluene 108883 %1.V w2— bWbt SSEF ty11.S.L 4't.5 Ethylbenzene 100414 'S NI xro tbsrobt SSEF -4O•-c IN. Xylene 1330207 t,..1,1/41‘017— ,,,tyrto1 barobi SSEF tt.`li:i ICS n-Hexane 110543 3.153)i 0.1 b.robt SSEF 1411.114.4 156N.S- 2,2,4-Trimethylpentane 540841 Ibs/bEl SSEF 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. 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLONADO ., _ - ,,,.,... ,, Pt t: z 5 14 c oil /t..- D • Permit Number: 19WE0770 AIRS ID Number: 123 i Ao7o i 001 • Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be oper d in full compliance with each condition of General Permit GP08. 1/11-.--..4 3)- °ec -I Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations Name(print) Title Check the appropriate box to request a copy of the: O Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 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: in Colorado Department of Public Health and Environment -- ieitiAnD, COLORADO 6 1 MAIO i."':i�.r. CDPHE Gas Venting APEN - Form APCD-211 Fa }. ef 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for gas venting only.Gas venting includes emissions from gas/liquid separators,well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source(e.g. amine sweetening unit, hydrocarbon liquid loading,condensate storage tanks, etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options wilt not satisfy your reporting needs.A list of all available APEN forms can be found on the Air Pollution Control Division(APCD)website at: _ 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: / I(t J f 077) AIRS ID Number: /.23 moo / G o z. Section 1 - Administrative Information Company Name': CCRP Operating Inc. Site Name: True Ranch Fee 2326H Site Location Site Location: NENE Sec. 23 T12N R65W Weld County: NAICS or SIC Code: 211111 Mailing Address: 717 17th Street, Suite 1525 (include zip Code) Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720)961-9100 E-Mail Address2: imyers@clearcreekrp.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.My 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. 4O2645 . ` v C01.001•00- Permit Number: 1; ��v 4. ,*( AIRS ID Number: 13 Acid rk Section 2 - Requested Action ID NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment O Change company name3 O Add point to existing permit ❑ Change permit limit O Transfer of ownership O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ID Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info I3 Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Combustion of gas from separator sent to enclosed combustor. Company equipment Identification No. (optional): For existing sources,operation began on: 4/25/2019 For new, modified,or reconstructed sources, the projected start-up date is: ®Check this box if operating hours are 8,760 hours per year;if fewer, fill out the fields below: Normal Hours of Source hours/day days/week weeks/year Operation: + Will this equipment be operated in any NAAQS ❑ Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes 0 No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No. 7, Yes ❑ No Section XI/11.G? //JnJJ��v COLORADO 5,PCE 211 C'i; 'vert .t;C.t".'�� Re u.ion°, ,.,;1S 2 I �:i� ..«.,y Permit Number: AIRS ID Number: �.t �:;i#1 ��,... fik,-16 Uu it Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/past ❑ Slowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes 0 No Vent Gas Gas Venting Heating Value: 14a6,c, BTU/SCF Process Parameterss: Requested: `1o.-s1 MMSCF/year Actual: 401 MMSCF/year -OR- Liquid Throughput Process Parameterss Requested: bbl/year Actual: bbl/year Molecular Weight: 29.59 1 q -+ VOC (Weight%) 51.54 Benzene(Weight%) 0.11lc Vented Gas Toluene(Weight%) 0.13 Properties: Ethylbenzene(Weight 0.O2i Xylene(Weight%) 0.05 ! n-Hexane(Weight%) 1.321 2,2,4-Trimethylpentane 0.000 (Weight%) Additional Required Information: J Attach a representative gas analysis(including BTEX&n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX&n-Hexane, temperature, and pressure) s Requested values will become permit limitations. Requested limit(s)should consider future process growth. COLOR ADO Form APCD 211 Gas Venting APEN - RevIsnn 7,2018 3 I COLD ADO ks pc.( ` . o...HA 4, ,-. V r'ck-44.t \vC ckk1 N� . 0+-4013 Permit Number: AI AIRS ID Number: kIttOVIt Section 5 - Stack Information Geographical Coordinates (Lotitude/Longitude or UTM) 40.996623/-104.535017 Operator Discharge Height Temp. Flow Rate Velocity Stack ID No. Above Ground Level (•F) (ACFM) (ft/sec) 35 2300 694 0.23 Indicate the direction of the stack outlet: (check one) 0 Upward O Downward O Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): 96 o Other(describe): Section 6-Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: 0 VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOCs and HAPs Rating: 42.5 MMBtu/hr Type: Endosed Combustor Make/Model: Crimson Energy CE-1000 Combustion ❑ Device: Requested Control Efficiency: 98 % SN' f„Eia�-cC.t?P—03% • "" or trd Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: tv,'s Btu/scf Constant Pilot Light: 0 Yes O No Pilot burner Rating: 0,04 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: Ay ��avwauu Farm APCD-211 ;as Venting APEN Revision 7 2318 4 i %h \ a(..S (4.0,co. ( t..,a‘i. I`A` t)5/i1,A10I O Permit Number: rttAXUll-\ AIRS ID Number: {LS 1 J-6 a 1- 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 SOS NOx CO VOC ECD 98 HAPs ECD 98 Other: From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP-42, Emissions Emissions6 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx 0.068 lb/MMBtu AP-42 13.5-1 `t.L3 41.1 5.01, 5.01 CO 0.31 Ib/MMBtu AP-42 13.5-1 tel.Z +9.t4 2..S It 't-3 t) gr•uiyi+Sr is 30 t1- itio,C°i VOC 541v1'41 5,5" Ib/MMSCF h,-�1t. fib.Li — Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Abstract Chemical Name Source Uncontrolled Controlled Service(CAS) Uncontrolled Units Number Basis Mfg., (pounds/year) Emissions6 etc.) (pound y ) (pounds/year) Benzene 71432 'io.tS lb/MMSCF Vent Das*rnisoons tdebt. t11..3 Toluene 108883 la>.3to IbIMMSCF vim au«mesons qS o.S tsl.5 Ethylbenzene 100414 lto.5"{ Ib/MMSCF Vont gas.ma.ans 1251.L4 1-4.` Xylene 1330207 LIL.41 IbIMMSCF Vonty.semissions 3r11.‘.. y1.9 n-Hexane 110543 t 055„dri Ib/MMSCF v.n gas omissions x,55.9 15 . 2,2,4- Trimethylpentane 540841 Ib/MMSCF volt gas*missions Other: 5 Requested values will become permit limitations.Requested limit(s)should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported.if source has not yet started operating,leave blank. COLORADO t!,-..-µ?,tu 211 ()as Verttng APEN � Re.isier 7 18 5 I ".�"" f?.tdt4.c• t,pa(atcc l c1' *cat 0A N Crlilioto Permit Number: Gi- i AIRS ID Number: 13 t JUt� Section 8 -Applicant Certification I hereby certify tha all information contained herein and information submitted with this application is complete, true,and correct.C A 144/ 2_00 ' Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations Name(please 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 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 or(303)692-3148 APCD-SS-B1 4300 Cherry Creek Drive South APCD Main Phone Number Denver,CO 80246-1530 (303)692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment h—Ds as ,, _I,:r;., a a-,. A D COLORAO Form APCD 211 Gas Venting APEN - Revision 7 2018 6 I Lia Rrcr-rvED DEC 312019 Ap IJ Produced Water Storage Tank(s) APT; ` �. rs Form APCD-207 mo COPHE 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. 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: Ai i f/ 7 AIRS ID Number: 123 /A070/003 t.,)14, .an .AFCC. ,f' , i, , ,.,a& lD; Section 1 -Administrative Information Company Name': CCRP Operating Inc. Site Name: True Ranch Fee 2326H Site Location Site Location: NENE Sec. 23 T12N R65W County: Weld NAICS or SIC Code: 211111 Mailing Address: (Include zip code) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720) 961-9100 E-Mail Address2: imyers@dearcreekrp.com 'the 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 will be issued by the APCD via e-mail to the address provided. 423847 c coloIAoo 1 =i::'..W.`r Permit Number: - MRS ID Number: 123 /A070/003 Section 2 - Requested Action ❑i NEW permit OR newly-reported emission source O Request coverage under traditional construction permit o Request coverage under a General Permit ❑ 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) -ADDITIONAL PERMIT ACTIONS- • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Storage of produced water prior to truck loadout. Company equipment Identification No. (optional): PWTAN KS For existing sources, operation began on: 4/25/2019 For new or reconstructed sources, the projected start-up date is: N/A Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration&Production(E&P)site ❑ 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 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? 0 Yes O No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) O 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)? S CD COLORADO F• rm;,PC3-107 Pr 'E,c- Water Sr)race•' Lint, APEN - Pe.is+f�n 1 2019 2 ICOLOR •D• Permit Number: . � .D'E'. AIRS ID Number: 123 /A070/003 Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Produced Water Throughput: 452,629 543,154 From what year is the actual annual amount? Projected Tank design: 0 Fixed roof O Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) 4 2,000 04/2019 04/2019 Wells Serviced by this Storage Tank or Tank Battery'(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 47411 True Ranch Fee 202-2326H 05 - 123 - 47413 True Ranch Fee 502-2326H 0 - - ❑ O s Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. 6 The 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) 40.998623/-104.535017 0 Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) Indicate the direction of the stack outlet: (check one) ❑Upward O Downward ❑Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) o Circular Interior stack diameter(inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): o Other(describe): COLORADO Permit Number: 1 oLk)`c ll- AIRS ID Number: 123 /A070/003 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): % I Pollutants Controlled: VOCs and HAPs Rating: 42.5 MMBtu/hr Type: Enclosed Combustor Make/Model: Crimson Energy CE-1000 ❑ Combustion Requested Control Efficiency: .8g cis % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 1,496 Btu/scf Constant Pilot Light: ❑ Yes O No Pilot Burner Rating: 0,04 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)? —30 psig Describe the separation process between the well and the storage tanks: 3-phase separators separate the fluid and natural gas. c_A •K to O,-W‘C.cit p=,P1- CoLOU•Do Permit to Number: ,. 1 AIRS ID Number: 123 /A070/003 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? QQ Yes O No If yes, describe the control equipment AND state the collection and control efficiencies(report the overall,or combined, values if multiple emission control methods were identified in Section 6): Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC ECD ' 100 •98-415 NOx CO HAPs ECD 100 -96- 1 S Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Emission Factor? Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis Units (AP-42, Emissions Emissions Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 0.262• Ibslbbl CDPHE 5929 • 4.1a"L.. §, 71.15 . -Hp 3_t;; NOx - 0.068 • 9YMMBIu AP-42 N/A 0,83 , N/A 0.99 CO 0 31 • 10/MMBlu AP-42 N/A 3.78 • N/A 4.53 . s Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth.Requested values are required on all APENs,including APEN updates. 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. 6 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-criteriaci Yes O No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Uncontrolled Service(CAS) Basis Units (AP-42, Emissions Emissionsa Number Mfg.,etc.) (lbs/year) (Ibs/year) Benzene 71432 0.007. Luew CDPHE 3 168 40 ea-sr ►re.ti Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.022 bs/bbl CDPHE 9.957.63• 344.14,9111 2,2,4-Trimethylpentane 540841 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. a Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. COLO11ADO Permit Number: AIRS ID Number: 123 /A070/003 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 GP05 or GP08, I further certify that this source is an ill Aerated in full compliance with each condition of the applicable General Permit. 3 ( -9<< -11 Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations 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 ;m^Y,. Cr ,: Tin ;s.; AFE:! tt,,... . : ;I 6 law Rrr.�f 4C3419 s, }pr Hydrocarbon Liquid Loading APEN,,,,,;') a tip 40 Form APCD-208 w. 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 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. 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: 2 v/rC l AIRS ID Number: 123 / A070 /004 Section 1 -Administrative Information Company Name': CCRP Operating Inc. Site Name: True Ranch Fee 2326H Site Location Site Location: NENE Sec. 23 T12N R65W County: Weld NAICS or sic Code: 211111 Mailing Address: (include Zip Code) 717 17th Street, Suite 1525 Denver, CO 80202 Contact Person: Ian Myers Phone Number: (720) 961-9100 E-Mail Address2: imyers@clearcreekrp.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.My 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. 423848 htLAMA COLORADO :I i. 4: n ! i. .i..i J Y�'i}t. ., - Y� Y 1 ilNlieltirV��ir....... Permit Number: ` OU( AIRS ID Number: 123 /A070/004 Section 2 - Requested Action ❑Q NEW permit OR newly-reported emission source 0 Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ 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) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Loadout of hydrocarbon liquid to tanker trucks Company equipment Identification No. (optional): LOAD1 For existing sources,operation began on: 4/25/2019 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? O Yes No Is this equipment located at a stationary source that is considered a Major Source of(HAP) O Yes (J No emissions? 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? Q Yes O No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes 0 No average? • Does this source splash fill less than 6,750 bbl of condensate per year? O Yes 0 No Does this source submerge fill less than 16,308 bbl of condensate per year? O Yes El No F m .:r r. ., N di:.„:arts ; L;c: P_.J kcv s rr '4 Permit Number: AIRS ID Number: 123 /A070/004 Section 4- Process Equipment Information Product Loaded: O Condensate 0 Crude Oil O Other: if this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 248,475 bbl/year Actual Volume Loaded: 207,062 bbl/year This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars"or"tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of ,F bulk liquid loading: Molecular weight of True Vapor Pressure: Psia®60 °F lb/lb-mol 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: lb/ft3 Load Line Volume: ft;/truckload Vapor Recovery Line Volume: ftl/truckload 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. Section 5 -Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.996623/-104.535017 0 Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Discharge Height Above Temp. Flow Rate Velocity Stack ID No. Ground Level(Feet) ('F) (ACFM) (ft/sec) Indicate the direction of the stack outlet: (check one) ❑Upward O Downward O Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) o Circular Interior stack diameter(inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): O Other(describe): o COLORADO 3 { .: Permit Number: AIRS ID Number: 123 /A070/004 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. j Loading occurs using a vapor balance system: Requested Control Efficiency: k Used for control of: VOCs and HAPs Rating: 42.5 MMBtu/hr Type; Enclosed Combustor Make/Model: Crimson Energy CE-1000 Combustion Device: Requested Control Efficiency: -98- ' % Manufacturer Guaranteed Control Efficiency: 98 % 201 eS Minimum Temperature: `F Waste Gas Heat Content: 3.536 Btu/scf Constant Pilot Light: 0 Yes O No Pilot Burner Rating: elni MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: Section 7- Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes O 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 (X reduction of captured by control equipment) emissions) PM SO. NO. CO VOC ECD 100 -98-c HAPs ECD 100 -se- 5 Other: ❑i Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane ❑Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-�2, Emissions Emissions' Emissions Emissions Basis Mfg.,etc.) (tons/year) (tans/year) (tons/year) (tons/year) PM SO. NOx 0088 6/111A8tu AP-42 WAG.ti 0.02 4W, 0 tj7 002 CO 0.31 6IlAMelu AP-42 w,►- (PC" -49A,O 1 y • VOC 0 104 NAM CDPHE 10 77 e3! 0-KM 12 92 its(>41 05 5 Requested values will become permit limitations or wilt be evaluated for exempt status,as applicable,and should consider future process growth_Requested values are required on all APENs,including APEN updates. 'Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. 4 Le co►o9.00 cksk‘kC,1.s G am. . ik Permit Number: AIRS ID Number: 123 /A070/004 i Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria0 Yes O No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions° Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.0001e wsrbbi CDPHE 37 27 e 4 i 1 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0.0016 wslbbl CDPHE 33130 -tee iw•or. 2,2,4-Trimethylpentane 540841 Other: 6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide projected emissions. Arok 't-Ur -"---""-`1-`l 4--1r> o5 iy T.J t.'3 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 GP07, I further certify that this source is and will be ope ted It..., ull compliance with each condition of General Permit GP07. II-q« -ill Signature of Legally Authorized Person(not a vendor or consultant) Date Ian Myers VP Operations 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 Hello