HomeMy WebLinkAbout20203713.tiff xye,f COLORADO
Department of Public
Health&Environment
RECEIVED
NOV 3 0 2020
Weld County - Clerk to the Board WELD COUNTY
1150 0 St COMMISSIONERS
PO Box 758
Greeley, CO 80632 .
November 23, 2020
Dear Sir or Madam:
On November 24, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Crestone Peak Resources Operating, LLC - Date 20H-O264 Battery. A copy of this public notice and
the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
OF 040,.
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe 4. li'
Jared Polls, Governor I Jilt Hunsaker Ryan,MPH, Executive Director
PU b I c Rev e L.) CG.PL-(-rP)rr�(vs f-R),pw(SM/E lcruC.x), 2020-3713
12.1. 1/20 �G(sk)
CM t 4.Y" Air Pollution Control Division
` - Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Crestone Peak Resources Operating, LLC - Dale 20H-O264 Battery - Weld County
Notice Period Begins: November 24, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Crestone Peak Resources Operating, LLC
Facility: Dale 20H-O264 Battery
Well Production Facility
SWSE of Section 20, Township 2N, Range 64W
Weld County
The proposed project or activity is as follows: Crestone Peak Resources Operating, LLC (Crestone)
submitted an application to modify an existing well production facility located in the ozone non-attainment
area. With this application, the operator is requesting to modify the existing condensate storage vessels in
addition to permitting the flaring of natural gas from the low pressure separators.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0343 Et 20WE0344
have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis
are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-
notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd®state.co.us
• Send comments to our mailing address:
Harrison Slaughter, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
re Department of Public
wa 1 I Health Ft Environment
O
f Air Pollution AControlDDivision
CDPHE
Deoartrrient CY Punt.Heallt'&trr rc+r/rlei1
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0343 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Dale 20H-O264 Battery
Plant AIRS ID: 123/9E16
Physical Location: SWSE SEC 20 T2N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
Ten (10) 500 barrel fixed roof condensate Enclosed
TANKS 001 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 10
g .„..„0, COLORADO
Mr Pollution control Division
MPHC
DeraafItTlent c Pubic tiegtth Er trtvtruttme-ti
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.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 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 NOX VOC CO Type
TANKS 001 --- --- 16.1 2.7 Point
Note:See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria pollutants, must be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder must calculate actual emissions
each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
7. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the
limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice(APEN)
and receive a modified permit prior to the use of any other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Page 2 of 10
LCRADoOt Division
GDPHE I
t DeElaiaOe*H CP Publx iteaOCt i 6 zworcorneni
Dedicated to protecting and improving the health and environment of the people of Colorado
TANKS 001 Enclosed Combustor(s) VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Process Parameter Annual Limit
ID
01 Condensate 74,460 barrels
TANKS 001 throughput
02 Combustion of pilot 0.7 MMSCF
light gas
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
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. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
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
Page 3 of 10
a - COLORADO
Air Pollution Control Division
G#YP
, DeY3rirTle±ll a aubb t fe31Slr&rrivlrcesne-1
Dedicated to protecting and improving the health and environment of the people of Colorado
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 (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 OEM 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) after issuance of this permit, the owner or operator
must complete site specific sampling including a compositional analysis of the pre-flash
pressurized condensate routed to these storage tanks and, if necessary for emission factor
development, a sales oil analysis to determine RVP and API gravity. The pre-flash pressurized
condensate sample must be obtained from the outlet of the low pressure side of the high/low
pressure separators. Testing must be in accordance with the guidance contained in PS Memo
05-01. Results of the analysis must be used to calculate site-specific emission factors for the
pollutants referenced in this permit (in units of lb/bbl condensate throughput) 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
Page 4 of 10
.I,-As _ 4 COLORADO
Mr Pollution Control Division
CDPH6
Defer a,trne'tt 0 Pubkk.Hesltli b Cru irurlffle-
Dedicated to protecting and improving the health and environment of the people of Colorado
established herein in the "Notes to Permit Holder" for this emissions point. If any site-specific
emissions factor developed through this Analysis is greater than the emissions factors submitted
with the permit application and established in the "Notes to Permit Holder" the operator must
submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request
for permit modification to address these inaccuracies.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit Existing New Emission Point
Number Emission Point
GP01 123/9E16/001 123/9E16/001
21. 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 (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
Page 5 of 10
COLORADO
Air Pollution Control Division
[WHS.
DEex3r'.ofle'a d PutGlr_'Etealtii B trim:Ali e-A
Dedicated to protecting and improving the health and environment of the people of Colorado
22. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Emissions - tons per year
Facility AIRS Equipment Current
Equipment poi nt Description Pollutant
IDThreshold Permit
Limit
Condensate
TANKS 001 Storage
Vessels
Produced
PW 002 Water
Storage
Vessels VOC 50 34.1
Condensate Hydrocarbon
Loadout 004 Loadout
Buffer 021 Separator
Venting
Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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
Page 6 of 10
As4.440
-« COLORADO
Air Pollution Control Division
fi6PHE.
DE•P3,trtrt8 o PUNK.Ftead[h Er Er'wtrvirneni
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
25. 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.
26. 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.
27. 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.
28. 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.
29. 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 Crestone Peak Resources Operating,
LLC
Permit for ten (10) condensate storage vessels
at an existing well production facility.
Page 7 of 10
a •- COLORADO
Mr Pollution Control Division
DPH#
DeCC3O rient O Pubic.hfeatth&Er viret?lnecl
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 1,867 93
Toluene 108883 1,400 70
Ethylbenzene 100414 101 5
001 Xylenes 1330207 455 23
n-Hexane 110543 12,751 638
2,2,4-
540841 35 2
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 6.94x10-2 6.94x10-2 AP 42 Chapter
13.5
Page 8 of 10
_ .4.:.,„ COLORADO
Pollution Control Division
CDPHE
Deth32tr.,f Pua1r'Neal?ti 6 Lr7vlrutuTle4t.
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
VOC 8.61 4.305x10-1 ProMax
71432 Benzene 2.507x10-2 1.253x10-3 ProMax
108883 Toluene 1.88x10-2 9.401x10-4 ProMax
1330207 Xylene 6.111x10-3 3.056x10-4 ProMax
110543 n-Hexane 1.712x10-1 8.562x10-3 ProMax
Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control
efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on
a site specific pressurized liquid sample, a site specific sales gas analysis and ProMax simulation.
The site specific pressurized sample used in the ProMax simulation was obtained from the outlet of
the high pressure side of the high/low pressure separator for one well at this facility on 01/16/2020.
The sample pressure and temperature are 106 psig and 89°F respectively. The site specific sales
gas analysis used as an input for the ProMax simulation was obtained from the facility on
01/16/2020. The sample pressure and temperature are 106 psig and 58°F respectively. The AP-42
Chapter 13.5 CO emission factor (0.31 lb/MMBtu) in the table above was converted to units of
lb/bbl using a gas-to-oil ratio(GOR) of 88.21 scf/bbl and a heat content of 2537.14 Btu/scf. Actual
emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput.
Process 02: Combustion of pilot light gas
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMSCF lb/MMSCF
CO 310.0 310.0 AP-42 Chapter
13.5
Note: The CO emission factor listed in the table above was obtained by multiplying the AP-42 Chapter 13.5
CO emission factor(0.31 lb/MMBtu) by a heat value of 1,000 Btu/scf. Actual emissions are calculated
by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas.
Pilot light gas fuel flow is based on a constant rate of 25 scf/hr for each enclosed combustor.Monthly
pilot light gas throughput shall be determined by multiplying this hourly pilot gas throughput by the
monthly hours of operation of each combustor. There are three (3) enclosed combustors, each
equipped with a single pilot light, used to control emissions from the condensate storage vessels.
Total actual emissions are obtained from the sum of emissions resulting from the storage
vessels and combustion of waste gas from the storage vessels (process 01) and the combustion
of pilot light gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
Page 9 of 10
O
g ; Air l.ua A a Control Division
PHE C
Ckiartrr7eril O PubPrL't'tetah tt trIviruoYfO=,A
Dedicated to protecting and improving the health and environment of the people of Colorado
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
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC
MACT HH Area Source Requirements: Not Applicable
Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63:National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Colorado Air PerrrOrttng Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only -
Review Engineer: Harrison Slaughter _
Package#: 427693
Received Date: 3/19/2020
Review Start Date: 9/15/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC Quadrant Section Township Range
County AIRS ID: 123 SWSE 20 .2N -:. 64
Plant AIRS ID: 9E16
Facility Name: Dale 20H-0264 Battery
Physical
Address/Location:
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment)Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRS Point# Permit#
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
APCD has already Emissions Source Type Equipment Name Control? APCD has already # Required? Action Remarks
assigned) assigned)
Permit Initial
001 Storage Tank TANKS Yes 20WE0343 1 Yes Issuance
Section 03-Description of Project
Crestone Peak Resources Operating,LLC(Crestone)submitted an application to modify an existing major well production facility located in the ozone non-
attainment area.With this application,the operator is requesting to modify the existing condensate storage vessel and produced water storage vessel sources
in addition to permitting the flaring of natural gas from the low pressure separators.This analysis only evaluates the condensate storage vessels.
With this application the operator is requesting to convert the existing GP01 coverage for the source to an individual permit.Additionally,the operator is
updating the throughput and emissions to reflect current conditions.Finally,the operator is updating the site specific emission factors with this application.
Public comment is required for this application because new synthetic minor limits are being established in order to avoid other requirements.
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) 0000 O O
Title V Operating Permits(OP) 00000 000
Non-Attainment New Source Review(NANSR) O O
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) O O O O ❑ .❑
Title V Operating Permits(OP) 0000 O 000
Non-Attainment New Source Review(NANSR) O ❑
Storage T ankjs)Emissions(nvestol y •
•
Section 01-Administrative Information
'Facility Aloe l0: 123 9E16 001
County Plant Point
Section 02-Equipment Descdption Details
Storage Tank Liquid `Conde dfe72:
Detailed Em'ssInns Unit Ten(10)400 barrel roof condensate stores q �� �::z,
storage vessels connected via liquid manifold.
Description: h.
Emission Control Device Enclosed Combustors) 9'x196, 4 "zx' "�""�
Description: 4`f UU�nb y U` „
Requested Overall VOC&HAP Control Effcienry%: 95,0
Limited Process Parameter _ _ 2,31
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= : 48,307.0 Barrels(bbl)per year -
'Requested Permit LimitThroughput= 74,460.9 Barrels(bbl(Per year Requested Monthly Throughput= 5326.1 Barrels)bbl)per month
Potential to Emit(PTE)Condensate Throughput= 74,460.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of wastegas= 2537.1:Btu/sc7
Volume of waste gas emitted per BBL of liquids
produced= 72.21 scf/bbl
Actual heat content of waste gas routed to combustion device= 262216.6 MMBTU per year
Requested heat content of waste gas routed to combustion device= 25.po3_B MMBTU per year
Potential to Emit(PIE)heat content of waste gas routed to combustion device= _6634 MMBTU per year
Control Device
Number of Combustors: 3.
Pilot Fuel Use Rate: 25 ccth 0.6579 MMscf/yr
Pilot Fuel Gas Heating Value: 1000 Btu/scf 65_:0 MMBTUJyr
Section 04-Emissions Factors&Methodologies
Will this store etank emit flash emissions? +-
ProMax Flow Rate 74,460.00 bbl/year
Pollutant Total Waste Gas Source
)lb/hr)
VOC 7318567263 PmMax
Benzene 0.213077 ProMax
Toluene 0.15981 proMax
Ethylbenzene :0.0114730 ProMax
xylenes 0.0519477 Preston
n-Hexane 1.45555 prooee
2,2,4-TMP 000402565 ProMa9
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 4.6162 6 Site 5pecificE.F.(includes flash)
Benzene 2 -.- fife SpecHCEF.{includes flash)
Toluene 2 2306-22 Site Specifi E.F(Includes flash)
Ethylbenzene 1.6602-26 - Sate SpecificE.E.(includes flesh)
xylene "611"1"3 Site Specific ES.(Includes flash)
n-Heoane I Site Specific ES.(Includes flash)
224TMP _4, 2 2 - . Site 5pedflc ES.(includes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/bbl) Emission Factor source
(waste heat (Condensate
combusted( Throughput)
PM10 0.0075 613 AP-42 Table 1A-2(PM10/PM.25)
_PM2.5 00075 _..r 49.42 Table 1.4-2(PM10/PM2.5(
509 0.0006 - AP-42 Table 34-2(50x).
NOx 0.0680 - A➢-4ZChapter l3-5 Industrial Flares(NQx)
CO 0.3100 1 62 AP-42 Chapter 13.3 Industrial Flares(CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/Mnescf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 - AP-42 Table 124-2(PM10/PM.2.5)
PM2.5 0.0075 AP-42 Table 34-2(PM10/PL25)
500 0.0006 AP-42 Table 1.4-2(Sox)
NOx 0.0680 AP-42Cha cher 13.5 Industrial Flares(NO1)
VOC 0.0054 AP-42 Table 1.4-2(VAC):.
CO 0.3100 AP-a2 Chapter 13.5 industrial Flares(CO)
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Perm a Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
' (tons/year) (tons/year) (tons/year( (tone/year) (tone/year) (lbs/month)
PM10 :8.065 3 043 ^6.045 1.055 62515 11.C
PM2.5 2.065 G.043 004d 0.005 0.0665 110
5Ox 0.905 0,0066 0.303 9.905 0.005 U.S
500 0.585 0.302 0,390 0.509 9.589 200:3
VOC 320.555 297.96'5 10.400' �x3 16.02263 2722.5 5,0
CO 2.6685 2777 L777 2."425 2585 456.8
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled •
)Ibs/yeer) (lbs/year) (lbs/year) (Ibs/year) (Ito/year) .
Benton _210.454 60.54& -222.365 9332E
Toluene 322 035 008.223 45.411 ..226 -9.357
Ethylbenzene 150 312 26-224 3.250 25 30.
)(ylene 413 062 225.228 144.761 28.750
n-Hexane 12751,613 62=2.163 423.607 T s-_' 537.532
224 TMP 35.265 22.826 1.144 138.2- 1.703
2 004 C:\Users\hslaught\Desktop\1239E16\ZOW E0343.CP1
Storage Tank(,$)Erniss=ons Inventory
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Sown resn=enz a rsermiz
Regulation 7,Part D,5ecnon I.C,D,E,F 5xe..c .Regui:�r
Regulation J,Part D,Section I.G,C Sfax'=". loft Regulation 7,Part 0,Section 11.B,Cl,: C.3
Regulation 7,Part D,Section II.C.2 %Arse, he ulac 0n 6.C.2
Regulation 7,Part D,Section ll.C.4.e.(l) Storage Tank is not subjtctto Regufa0on7.Part 0,Section II C.4.alil
Regulation J,Part D,Secdon 's-,,,e siee,eo Regulation 7,Part D,Section b-f
Regulation 6,Part A,N5P5 Subpart Kb
Regulation 6,Part A,N5PS Subpart 0000 c.:0 NSFSOOOO
NSPS Subpart 0000a .. ..x sebjecztb NSP5OOOua.
Regulation B,Part E,MACr Subpart HH -not subject to MACCHH
(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
r
estimate emissions? ..,;fi7o
If yes,are theuncentralled actual or requested emissions for a crude oiltank estimated to be greater than or equal to 20 tons VOC per year OR are the uncontrolled ,
actualorrequestedemissionsforacondensato 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 an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions? .zYes.
if yes and'd 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 liberationanalysis(?This sample
should be.considered representatte which:generalN means site-specific and collected within one year of the application received s '
date.However,if the facility has not been modified(e.g.,no new wells brought an-line),then it may be appropriate.to use an older •eexsite-specific sample.
if no,the permit will contain an"Initial Compliance"testing requirementta develop a site specific emissions factor based on guidelines in P5 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 andgieriodie compliance testing in aaordance with PS Memo 20-02
Section 08-Technial Analysis Notes
1.According to the application,eleven all wells produce to the facility.The names and API numbers of the wells are available for reference on the condensate storage vessel APEN submitted on 03/19/2020 According
to COGCCdata,the wells at this fadlitywere fractured between December 2014 andlanuary 2015.The wens began production b March 2015.Six(6)wells produce from the Niobrara formation,four(4)produce from
0.': the Codeli-Fort Hays formations,and one(1)produces from the Niobrara-Codel4fort Hays ormations.
°s5 ,"2-Theite specffic pressurized liquid sample used to establish emissions factors for'this obtained within a year oftit ppll ati n.The samplebe ed from the utlet ofth high p d of one
high/low pressure separator etthb facility on 01/16/2020Addrt lly the ple was obtained after ail the Ih atth si lty began production.It shouldid b ted that the amp(includes mpl probe
o . temperature and pressure in conjunction with gauge pressure andtemperature.According t lab information,the pl probe temperature a d pressure are obtained using lab equipment d ing the pl g p ess.
. .,,These I e expected to be moretccurate compared t the gauge d are acceptablefor use in the uIb to eeabish site specific & factors.This pressurized liquid sample and a salesgas sample
r°obtained fr the fealty on01/16/2@O Were used as put values for the ProMax simulationd to develop th t p lib emisionfactors According.PS M 14-03 Section 5%the samples wed to develop
,sne specificemissions factors must beeobtained as follows:"Samples of low pressure oil,which Is p fl h pressureedol obtained from the separator outlet t the sales tonic must betaken during normal operatng:.
th� _:conditions."In this case,the low pressure side of the HLP separators the last stage of separafion forth forthe condensate pre to being routed to th [ ge vessels.As a result,the sample used to develop ene specific
emissionfactors should have been obtelned from the outlet of the low pressure side of the HLP separators.Snce the sample k site specific and the ProMaxsimulation was designed in an acceptable manner,the
emission f actors were accepted forpermROng purposes However,the permit will contain initial testing to confirm the accuracy and/or c0rservetbenature of emission factors estabished through this analysis due to
thesampling requirements listed In P4 Memo 14-03.It should be noted that a small amount of liquid 5 routed to the storage vessels from a buffer house(liquid knockout for vapor vented from low pressureseparatars).
The operator indicated that this liquid&at the same pressure as the liquid at the outlet of the low pressure separators.Cue to this,obtaining the initial sample from the outlet of the low pressure separators was
deemed appropriate for representing the composition and resulting emissions of the entire liquid throughput routed to the storage vessels.
3,Inlay:andcontrol deuce are addressedthe 0&M periodic ysbleemisions checks for thec byplan.Asaresuh,the permit d rot cnntein moral or periodic opacly testing.
4.The hydrocarbon laadout,separator venting and condensate storage vessels are controlled by the same enclosed combwtarsat the facility.Engineering guidance dictates that plot light emissions should be grouped
with the highest emitting source when sources are controlled by a commoncontrol device In the case,the highest emitting m Geis the condensate storage vessels.As a result,the plot light combustion emssions are
included in this analysis.
5.A throughput limit included in the permit for pilot combustion.Emission factors andcalculation methods for pilot light combustion emissions are also included in the notes to permit holder.Thb information is
included in the permit because pilot light emosons contribute to the overall emissions From the source.Additionally h a im portantto includethls information because throughput tracking and emaioocalculaton
methods are different than those used to estimate emissions based on the condensate throughput.This clarity is importantforaccurately quantifying actual emissions at this facility.
6.Engineering guidance indicates that NO3 and CO embsions from each source controlled by a corn mon control device need to be added together to evaluate APEN applicability.Total CO emissions from all sources at
this facihty that are controlled by themnclosed combustors(condensate st0ragevessels,separator venting and hydrocarbon badout)are greater than APEN thresholds.As a result,the permit for each source controlled
by the common control device will have limits on CO emissions.Total NOx emissions from all the sources controlled by the enclosed combustors are below APEN reporting thresholds.As a result,the permit will not
main,emission limns or emission factors for Non,
7.Ethyibenzene and 224TMP emissions are below APEN reporting thresholds(i.e.n 250 lb/year).As a result,the permit will n t contain emission factors for rump polluaneo:
a.R should be noted that an embsioo fectorfor VOC associated with pilot light combustions not incorporated into the permit This is due to the fact that the pilot light only results in a negligible contribution of VOC
(0.002 tpy).This minimal amount ofembslons does not Impact the total VOCllm0 forthis source and therefore can be ignored.
e,Actual emissions reported on the APEN are calculated using previously approved emission analysis does notn incorporate an evaluation of actual emissions.Therefore,the actual emissions In this analysis
do not match with the information an the APEN.As a result,actual emissions for this source should be referenced on the APENsubmitted on 03/19/2020.
10.The operator,.provided with a draft pe h and APEN redline to review prior to public nt The operator reviewedboth e is and exprwsed they h d no comments. y•
p'
Seddon 09-See Coding and Emissions Factors(For Inventory Use Only(
Uncontrolled
Emissions
AIRS Paint Process 0 5CC Cede ..�v Pollutant Factor • Control%Units
01 .brf-5q$vk'ffios eoRTas 4e fls ft_ r�yl fiHgfrl4ks€ r PMlO 004. 0 b/1,000 gallons Condensate throughput
PM2.5 0.04 0 b/1,000 gallons Condensate throughput
SOx 0.00 0 b/1,000 gallons Condensate throughput
NOx 0.38 0 b/1,000 gallons Condensate throughput
VOC 205 Off 95 b/1,000 gallons Condensate throughput
CO 3.72 D b/1,000 gallons Condensate throughput
Benzene 0.60 95 b/1,000 gallons Condensate throughput
Toluene OAS 95 b/1,000 gallons Condensate throughput
Ethyibenzene 0.03 95 b/1,000 gallons Condensate thro ughput
• Xylene 0.100 95 b/1,000 gallons Condensate throughput
n-Hexane 5.08 90 b/1,000 gallons Condensate throughput
224TMP 0.01 9S 6/1,000 gallons Condensate throughput
3 of4 C:\Users\hslaught\Desktop\1239E16\2oWE0343.CP1
•
.,.
_°',
StorageTank geg6lat3ry Malysls Worksheet
The regulatory requireme.below ore determined based an requested a missions,
caloaau 'I.i..,....t...................... uw;mmonn
2.13t e6Ni
v eummtroN s1m muro emA.r3M1.nzipY(eeeumona ron0.acuan o_l ale
x setethe annm= 1 l 2/ en ssoam arca mi miMama nions
Mal hbonn uanelnama Semmtbn addnow guidance on v+natnnermp"rob ryle
1.Netmal face Pr n14iW urea wnhxbnt veuermmaaiPr'Regulation Paete.xabn 103D
ry3N nnncom6N[
1.Ale uncontrolled emwaans horn any erderlap w[anu from rnwxarvleu.lsnns greater Ilan lrn lxe+huuaa,Pan n.senwn 0.0301? 'as ru peeolrn anraPN.solo[han qu on
2.Is the e larvketlnal pror to 12/30/1002 and not moellee aher.31/am11se m PS memo 0s4elan n m ionserz area and Sea 1loraaatana guaanee on eraMltther app'ch ityl? r
3.Aetna ls3 M tinmronro ernIssions greater than zrpy.n rgrettathan 5022/or CO emlwm;sgreatn titan IOiPY lneeulmon 3,Pan e,sawn AMA, rest..•. Source xepWres a permit
1.Is IN,stmage tank too.In the3-.ozone 023/ma
2.Is.storage tar.local.ate,a a gas operroation[n.1"6 store,erlhmale hydrocarbon Ile Ids or produced water MD that al eel=uoea,o.uonreamhof a"aural ors pcessmg pl+ntlaeeulauon 7.Part M,smon LAO aalNytvpeunmepmp+ummaryaneecary
processing pl nMeguxtwn?.Pan o,semon 1.61? _§orage rank isnot sublen to Regulation',Part M.Salon n0 vw navelnmatea',AMY tope on projet summay sheet
5.13am.this 5303age tank exhibit'Fla rA"(e.+ronn3 nonnablll3641171x.).emissions laegulauon 7,partv.sxmn 1.0.x1?
6.Pre uncontrolled ml Ions per yn oc(ueubtbn7.Pan M....1.03.a11111?
Part Sullen I.C.1—General Requirement.,ql,1131Ion control Equipment—Prevent.of Lea33ge
Part IA Seaton monitoring
Part 0,Soction LP-Moan...1,6+nd RePerring
Par t sect.I.C.I.aantl la-General Requirements larAir Pollution Control rAlpment-Prevention Af Leakage
bra
transmisslan/storaca faellIty3ou eprolem a
3. aora
rs t
e tan ,well proaunlonla�ry+,ntrl[asmmvresvruumn orraturilypror:sslnephnt 111eeunuen J.pan O.swenll.cl? uMva mdw[eeeulMrvp np ownsummarv+rent k have a fixed 9.Ana uncontrolled l�A m sstorageta. arrow greater tnA,xte.per year VOe leegY Eton?Par[M Se
ction tai cl) YeeSour.A subjectut plans n ugu a[nne,Pon M,sectbn 3wenon0o to the n quit inn
nndan Prouwlon+ "rand Prmmnonof Emisaons
s.oust a Infra as Alegutation,Aart 0,senionll.6.68/7 No Ix rce h sugeamall proWsio33 ofee4wtlun,,Part M,semen ll,04bmaions AC •
Pad 0.santm 0.C.2-Capture and Moniunneferv"rage oars imM with elrPollution Cm...Equipment •
mMdled On Dreher May 1,0210. Ina 6.L' ,tan dad h:Zr nt'letlnoroe algid:It'Tout ornAlt"eab0n q P cancer: 173 ,ion J.wn M,aSo% Aeazl) Na ape iantunotmgen to eeeuu"n)wrtM seabn<.a
nv ra a mpmv [tt n 0rna gpwm ronnrunae onoreh
ed '.ejy onomw No J Llo1 lotto nvaau M1rouenpul of hyaracarbon qua p uatl waarinegu rzmnc7 wrt0 eenbnhr[gailml?I
1.Is the indIMLtal Lange vessel cap.,greater<lunar er,ual to 75 euhic mr'htn
mtenl'I1 A72 IRAs,(AO CM 60,11013(a),,
x.Moe+ 11b(allgli vest s ae=r nk l+no[suelen nspsgb,
02'1^10,002 e.2/used e,proussea.or tree pl l°cola./lraoiler as defined In 60.1111,
3.Wu.szorage ru modified Dredge..?w Sfei6vSlaherlulvlea mac on re.°smairi,ua NA
nv vhf lFe delml
1q Ivo11','i h)
6 m vessel0+1,9.2 pal an Avon o atmosphere 46/48011?.o NF
r #'1^37 331 an 9a 86/43166: 063:6: / 64667611041637.:,
,n'1'aneey h"4 les+otfan 151 niq-em e3D and stoma 176evnth a mammum true wpreaure wa than 3641,611.13.130,
).Dees ank meetenretone eortthe following exemplars from control requrements: Wa.
a.mad r m•(9s 6 L1 and stores.q WW amssbn per unsure greater Alan or equal was"P WTIAA,than sl 4067.or
storage
Io)sm'1-an Rey ail wss[nm ash m'I'9w 33[1 an ttme al qupe wunama.mumhuevavafvjennaere.7/66 ama6/46373 hm esstha,276wa) Nn: +^>:�PI 1.INA...rage wenn!located At facIllly the onshore antl natural gas production a0[Pn Panw,subwn 0000/o0oou,stanmrds of vonormaneolu.enah avana N+m.ala..Pmaunlmr,r.ausua+lon mavlldlartwn -
slop ands raw segment of Ne Industry) sated the source category o"the project summary sheet.
a.was mis ear..scram constructer,reccartimma,cr maims dal segment.
memeer mi as? to the euemm�a.
red pee aefinimarea 60.11aher September 1ez01s,ma
e vess.r.ter
than or equal
qu'met n perrear) tank h not subject N6Pe MOW
A Does. weasel meet the 6.hth. aeK plea accord aw.raguremen.terstompAnsel§n 90 UP part 30 Subpart or40CFP Pan 65 Subpart NA? --
.ore:na storage w++e14 prevxrvry determined to sugee3o MPS 0004/00002 due to emh+lons above 6 um 6843,V4Emmeapplka63M denomination due,hshoue romaxwhlat to MPS 0033/3400.per
60.3663/6N11/64.6366a16)I6levea lollemw1704em hsbn drop below 0 tom pnyaml
ag,Part 63,Subpart NIAMAI,Atand Gas Produclion PALM,.
1.wines an o an wing crania. F'• �<unMue You M1ave lna.ateaue+ewceoteeorven lee Pmjensummarysnen.
a a3 64 A p upgrades or stores hyamorbon Gq 1es'n163te601a11aIL06
facility lox promres,upgrades or stares naval gas pdorto the point al AAAAnaural gm enters the natural astranu"kaon ananoagenurce ojegoty or heenared m a3'nal ma usee,(6iJ6gaA3P
Z.Isl.-tan,located al afacAly that mabrmr NAN, raver nkl+na r.gea mN[r nx rherearenomnnx m mmt+brtankaat area,mron A Doesthe rank meet the definItion of,terage vessel'In 61.7612
Does.e.rank meet the delinttlog of'storage vessel A.thepotential!or N.emisslone'pAr nhe subje rt63.subpar.,or pan MC00026R
6 _ N0.
.nkl
pv bte
663.?ea wlnA
03,66-Emssions[omnrlolstandards
453.,2-3,7,43 pxg
g6a,ns�Papanlne
Peer midwrs RAW.amgulatgo"J does not EPA•ANonthu tank b inthanonanoenment ama,lltne tan..1312..ada,man miavpnnrequbemmu,
Disclaimer
This dacumentesslsh operators Mil;d4Mminirg app&.billy M1arlelnrywemenw ofMMaclem Nrgcl,i s Implementing reg..,,and Air Duapycmxrol Cornssim repuNg*Thls docvm.nl
• �a iand
e ana if 0,1102 may nut apply lo.pacenfar deaon basal umMei..alNOsend akunumrcm.iMs occur'''.does rwentateemsudswrja ra.rylew,rsywenm.
dydM6Q�IelNWadnpre?waysls mnt.ntlr:muep3 yen/crab.In3e event eny44148 Men the league.edllds tlocvmenlarq a)elenBuap.dlhecl.en44403 Its impbmmllnpryWafim;
y cwwol corm,mans,lhalenu a espalula w rep.. will control.The use, aurhas'rxvmmaM;'may,"slroWm,'antl'ceuk'ia iMeaMm
asolbe Mao;warp.lawens andrtmmrrerd.ubns.Madela'y b-minlupy such as'must'end y,wm'areln.ded memnibecmbaingrepMenm urea tlrela.ss dine Cleo svgcjaMM
QM),Con.Cmxmsstm repuleVons,',tools document de.sml Estee.legally'Ming M1 iea..in.M Mif.
, COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Crestone Peak Resources •
Company Name Operating,LLC
County AIRS ID 123 History Flle Edit Date
Plant AIRS ID SEIB Ozone Status Non-Attainment
Facility Name Dale 20H-O264 Battery
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 ADS SO2 NOx VOC Fug CO Total PMIO PM2.5 H25 SO2 WOO VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL •
Previous Permitted Facility total -:
,+,1 200JEUTAB Tad(19)900 trlA IL".,t, ,:t v'! 0,0 0,70,11 2.7 0.7 0,1 0.1
ccr0densat0 sdnrxg0 e0S0.01.
11177. G},15 'FOX{S}2,603>g141 "aipruc?Uu'.:3 1 0.2 10.0 ,.
01310r 595O95O'2: Urullli 1,ru1110.,.t ,.
003 15WE1216,CN Fugitives 0.2 O E 0.2 0.0 Cancellation received 03119/2020.Emissions are
below APEN reporting thresholds.. ..
004 15WE1217 Hydrocarbon Loadout 0.1 559 0.4 3.2 0.1 2.8 0.4 0.2 No Change
005 GP02 CN SI RICE GM FX10,4565,92 HP,SN: 0.0 DO Cancellation received 7/2412017,Source no bnger
10CHMM41 051 0 05 3 exists at thetacliity.
2OB GP02.CN `SI RICE GM FX12,4SRB,92 HP,SN: '' 0 0 0.0 Cancellation received 12/24/2015.Source no longer
10CHMM405270009 abate at the facility.
007 GP02.CN SI RICE GM FXI2,4098;92 HP,SN: OA 00 Cancellation received 12/24/2015.Source no longer
10CHMM40527009G exists et the facility.
008 GP02.CN SI RICE GM FX10,4SRB,92 HP,SRI 0.0 ' 0.0 Cancellation received 12/24/2015.Source no longer
10CHMM3 031 8 0 03 3
azists at the facility.
009. GP02.CN SI RICE GM FX50,4SRB,92 HP,SN: 0.0 0.0 Cancellation receNed 12/24/2015.Source no longer
•
100HMM201120054 . exists at the.facility.
010 GPO2,CN SI RICE GM FX10,4SRB,92 HP,SR: 0.0 0.0 Cancellation received 12/24/2015.Source no longer
10CHMM21t150045 :,.. exists at the facility.
011 GP02.CN SI RICE GM FX10,4SRB,92 HP,SR: 0.0 0.0 Cencellalon received 7124/2017.Source no longer
10CHMM407150071 - exists at the facility,
012 GP02.CN SI RICE GM FX12,4SRB,92 HP,SR: 0.0 0.0 Cancellation received 12/24/2015.Source no longer
10CHMM405270014 . - exists at the facility.
013 GP02.CN SI RICE PSI 5.77 NA,4SRB,94.3 HP, . 0.0 0.0 Cancellation received 03/19/2020.Source no longer
SN:57L0510573 - - exists at the facilely,
014 GP02.CN SI RICE PSI 5.7L NA,409B,94.3 HP, 0.0 0.0 Cancellation received 03/19/2020.Source no longer
SN.5.7L0010574 exists at the/solely.
015 GP02.CN SI RICE PSI 5.7L NA,4999,94.3 HP, 0.0 0.0 Cancellation received 03/19/2020.Source no longer _
'EN.5.7L0010576- exists at the faddy.
016 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0 0.0 Cancellation receNed 03/19/2020.Source no longer
EN:.5 7L0010585 exists at the faciity,
017 GP02.CN SI RICE PSI 5.7L NA 4099,94.3 HP, 0.0 - 0.0 Cancellation received 03/19/2020.Source no longer
SN:5.770010601 exists at the bodily.
018 GPO2,CN SI RICE PSI 5.7L NA 4SRB;94.3 HP, 0.0 00 Cancellation received 03/19/2020.Source no Iorger
SN:5.7L0010579 edsle at the facility.
019 GP02.CN' SI RICE PSI 5.77 NA 4SRB;94.3 HP, 0.0 0.0 Cartoeliation received 03/19/2020.Source no longer
SN:5.770010587 exists et the facility.
020 19i/1160254.GS SI RICE Compress.03230,40128; 0.0 0.0 Cancellation received 03119/2020.Source no longer
46 HP,SIX:T80
exists at the facility.
I i., e.R I Ituant5h 1110
XA Separator Heaters 0.2 0.2 2.4 0.1 2.0 0.0 0.2 0.2 2.4 0.1 2.0 0.0 Insignificant Source
FACILITY TOTAL 0.3 0.3 0.0 0.0 3.3 479,4 0.2 6.1 14.3 0.3 0.3 0.0 0.0 3.3 34.1 0.2 6.1 1.6 XI,C: / or(3>PilI 0,,,,,11:11 4,4',17
111910:1 ! ,>r If^`Oft ."i,.I
Permitted Facility Total 0.1 0.1 0.0 0.0 0.9 479.3 0.0 4.1 14.3 0.1 0.1 0.0 0.0 0.9 34.0 0.0 4.1 0.9 Excludes unto exempt from permits/APENs
(A)Change in Permitted Emissions -0.6 -0.6 0.0 0.0 -6.1 -22.0 -1.4 -11.9
Total VOC Facility Emissions(point and fugitive) 34.3
(A)Change in Total Permitted VOC emissions(point and fugitive) -23.J .,
Note 1
Note 2
Pugs 101 3 Printed 11/10/202(1
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123
Plant AIRS ID 9E16
Facility Name Dale 20H-O264 Battery
Emissions-uncontrolled(lbs per year)
POINT'PERMIT IDescription Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
Previous FACILITY TOTAL 0.0 0.0 0.0 1.4 1.5 0.0 0.5 6.9 0.0 0.1 0.0 0.0 10.5
001 20WE0343 Ten(10)500 bbl fixed roof condensate 1867 1400 101 455 12751 35 8.3
storage vessels
002 GP05 Six(6)250 bbl fixed roof produced water 192.7 91.8 333 10 93 0.2
storage vessels
003 15WE1216.CN Fugitives 1 2 2 7 0.0
004 15WE1217 Hydrocarbon Loadout 1051 1856 78 816 2605 3.2
005 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM4 10510053
006 GP02.CN SI RICE GM FX12,4SRB,92 HP,SN: 0.0
, 10CHMM405270009
007 GP02.CN SI RICE GM FX12,4SRB,92 HP,SN: 0.0
10CHMM405270096
008 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN:- 0.0
10CHMM303180033
009 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM201120054
010 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM211150045
011 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM407150071
012 GP02.CN SI RICE GM FX12,4SRB,92 HP,SN. 0.0
10CHMM405270014
013 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010573
014 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010574
015 GP02.CN SI RICE PSI 5.76 NA,4SRB,94.3 HP, 0.0
SN:5.7L0010576
016 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010585
017 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5,7L0010601
018 GP02.CN SI RICE PSI 5.76 NA,4SRB,94.3 HP, 0.0
SN:5.7L0010579
019 GPO2.CN Si RICE PSI 5.76 NA,4SRB,94.3 HP, 0.0
SN:5.7L0010587
020 19WE0254.CN SI RICE Compressco GJ230,4SRB,46 0.0
HP,SN:TED
021 20WE0344 Natural gas venting from the low 555 329 16 54 4195 2 2.6
pressure side of eleven(11)HLP
separators&routed through the buffer
house.
XA Separator Heaters 4 137 0.0
TOTAL(tpy) 0.0 0.0 0.0 1.8 1.8 0.1 0.7 9.87 0.0 0.0 0.0 0.0 14.3
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de minimus
2 1239E16 11/10/2020
•
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT -
AIR POLLUTION.DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123
Plant AIRS ID 9616
Facility Name Dale 20H-O264 Battery
Emissions with controls(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 0.1 0.1 0.0 0.0 0.4 0.0 0.0 0.0 0.0 0.6 -_
001 20WE0343 Ten(10)500 bbl fixed roof condensate 93 70 5 23 638 2 0.4
storage vessels
002 GP05 Six(6)250 bbl fixed roof produced water 1927 9 i.8 3.6 10.7 93 0.2
storage vessels
003 15WE1216.CN Fugitives 1, 2 7 0.0
004 15WE1217 Hydrocarbon Loadout 53 93 4 41 130 3) 0.2
005 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM410510053
006 GP(12.CN SI RICE GM FX12,4SRB,92 HP,SN: 0.0
10CHMM405270009
007 GP02.CN SI RICE GM FX12,4SRB,92 HP,SN: 0.0
10CHMM405270096
008 GP02.CN, SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM303180033
009 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM201120054
010 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM211150045
011 GP02.CN SI RICE GM FX10,4SRB,92 HP,SN: 0.0
10CHMM407150071
012 GP02,CN SI RICE GM FX12,4SRB,92 HP,SN: 0.0
10CHMM405270014
013 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010573
014 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5,7L0010574
015 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010576
016 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010585
017 GP02.CN SI RICE PSI 5,7L NA,4SRB,94:3 HP, 4.0
SN:5.7L0010601
018 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010579
019 GP02.CN SI RICE PSI 5.7L NA,4SRB,94.3 HP, 0.0
SN:5.7L0010587
020 19WE0254.CN SI RICE Compressco GJ230,4SRB,46 0.0
HP,SN:TBD
021 20WE0344 Natural gas venting from the low 28 16 210 0,i 0.1
pressure side of eleven(11)HLP
separators&routed through the buffer
house.
XA Separator Heaters 4 137 0.0
TOTALf(tpy) 0.0 0.0 0.0 0.2 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 1.0
3 1239EI6 11/10/2020
;�v COLORADO
I Mr Pollution Control Division
CbPHE
Cr-,,corrtel.a,Plibk Itealrh 8 nvfn:rut,e 1
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0344 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
a
Facility Name: Dale 20H-O264 Battery
Plant AIRS ID: 123/9E16
Physical Location: SWSE Section 20 T2N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Equipment Description Emissions Control
ID Point Description
Flaring of natural gas vented from the low
pressure side of eleven (11) high/low Enclosed
Buffer 021 pressure (HLP) separators and routed Combustor(s)
through the buffer house during vapor
recovery unit (VRU) downtime.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS)form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self-
- Page 1 of 11
-r' jC€1LORAD4
Air Pollution Control Division
DPHE
Depaanznl a'tutee tieOli ft trivu tufe^.1
Dedicated to protecting and improving the health and environment of the people of Colorado
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. Within one hundred and eighty days (180) after issuance of this permit, the operator must
install a flow meter to monitor and record volumetric flow rate of natural gas vented from
low pressure side of each HLP separator and routed through buffer house to the enclosed
combustor(s) covered by this permit. Until the flow meter is installed, the operator must
monitor and record condensate produced through the separator and estimate the gas flow
rate based on the standard cubic feet (scf) per barrel (bbl) of 38.2 scf/bbl estimated in the
permit application.
5. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
6. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
Buffer 021 --- --- 5.1 1.0 Point
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria pollutants, must be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
• based on the previous twelve months' data. The permit holder must calculate actual
emissions each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
Page 2 of 11
,. :,, COLORADOluti
AiControl
oDivision
CDPHF
Der..aarneli ce PubTr_tiealitI b=rlvi, ne`711
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and demonstrate compliance with the
limits in this permit. The owner or operator must submit an Air Pollutant Emission Notice
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
9. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants
ID Point Controlled
Emissions from the low pressure side of
eleven (11) high/low pressure (HLP)
Buffer 021 separators are routed through the buffer VOC and HAP
house to enclosed combustor(s) during
vapor recovery unit (VRU) downtime.
PROCESS LIMITATIONS AND RECORDS
10. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
Section II.A.4.)
Process Limits
Equipment ID AIRS Process Process Parameter Annual Limit
Point
Natural gas vented from
the low pressure side of
Buffer 021 01 the HLP separators and 2.9 MMSCF
routed through the buffer
house to the enclosed
combustor(s)
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
Page 3 of 11
a„.„,,,,„ ` COLORADO
Air Pollution Control Division
DP P"
Cleo nrfler,c o Bubb_tieditti b€rwruttrrte^A
Dedicated to protecting and improving the health and environment of the people of Colorado
11. Upon installation of the flow meter, the owner or operator must continuously monitor and
record the volumetric flow rate of natural gas vented from the low pressure side of the HLP
separators and routed through the buffer house to the enclosed combustor(s) using an
operational continuous flow meter. The flow meter must be calibrated and maintained per
the manufacturer's specifications and schedule. The owner or operator must use monthly
throughput records to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
15. The separators covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the commencement of operation by air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
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
Page 4 of 11
z COLORADO
40 Air Pollution Control Division
CbPHE
LDt,arltrie,tt 5-Put A4 Heetr E.ttty?ict rfl d
Dedicated to protecting and improving the health and environment of the people of Colorado
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 OitM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, 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
Page 5 of 11
' COLORADO
Air Pollution Control Division
DPHE
Def.xigmer-it V Ruble He3eti Er trp.rcorru ;'.
Dedicated to protecting and improving the health and environment of the people of Colorado
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Emissions- tons per year
Facility AIRS Equipment Current
Equipment Pollutant
ID Point Description Threshold Permit
Limit
Condensate
TANKS 001 Storage
Vessels
Produced
Water
PW 002
Storage
Vessels VOC 50 34.1
Condensate Hydrocarbon
Loadout 004 Loadout
Buffer 021 Separator •
Venting
___ __ Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
Page 6 of 11
a , COLORADO WO ,
Air Pollution Control Division
Lreuatlrtin.Cy RuLie'Ffeallh b trrom+vrie-v
Dedicated to protecting and improving the health and environment of the people of Colorado
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self-certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self-Certify for Final Authorization section
of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate. ,
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Page 7 of 11
„. ..„„eiCOLORADO
Air Pollution Control Division
cDPNE
De':inri e 0 o PuL fie-am'b crrolrcc me”
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit Engineer
Permit History
Issuance Date Description
Issued to Crestone Peak Resources Operating,
LLC
Issuance 1 This Issuance Permit for flaring of low pressure gas vented
from the low pressure side of HLP separators at
an existing well production facility.
Page 8 of 11
. . COLORADO
Air Pollution Control Division
a
Cauanri2ant cx Putrt•tieel h E.=rivvcrtme^'J.
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 555 28
Toluene 108883 329 16
Ethylbenzene 100414 16 1
Buffer 021 Xylenes 1330207 54 3
n-Hexane 110543 4,195 210
2,2,4-
540841 2 0.1
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 11
aCOLORADO
Air Pollution Control Division
Crtexantrre,:t 04 PUG:.Health b>_nvirLgrtn.
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 021:
Weight Uncontrolled Controlled
CAS # Pollutant Fraction Emission Emission Source
(oh) Factors Factors
(lb/MMSCF) (lb/MMSCF)
CO --- 675.06 675.06 AP-42 Chapter
13.5
VOC 69.035 70,113.72 3,505.69 Gas Analysis
71432 Benzene 0.1885 191.44 9.57 Gas Analysis
108883 Toluene 0.1116 113.34 5.67 Gas Analysis
110543 n-Hexane 1.4244 1,446.65 72.33 Gas Analysis
Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control
efficiency of 95%. The VOC and HAP emission factors listed above are based on a site specific
extended gas analysis obtained from the outlet of the buffer house (liquids knockout for low
pressure gas vented from the low pressure side of the HLP separators) on 01/16/2020. The
weight%values and molecular weight (38.4921 lb/lbmol) from the sample along with the
displacement equation (EPA Emission Inventory Improvement Publication: Volume II, Chapter
10) were used to determine the emission factors. The CO emission factor listed in the table
above was obtained by multiplying the AP-42 Chapter 13.5 CO emission factor (0.31 lb/MMBtu)
by a higher heating value of 2,177.6276 Btu/scf. Actual emissions are calculated by multiplying
the emission factors in the table above by the total metered low pressure gas vented from the
low pressure side of the HLP separators and routed through the buffer house to the enclosed
combustor(s).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: http://www.ecfr.gov/
Page 10 of 11
. ' COLORADO
40 1 Air Pollution Control Division
MP He i
( DE'.winvent&Pub1k:Hea1th&t:rt orLru'rs8-'A
Dedicated to protecting and improving the health and environment of the people of Colorado
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Harrison Slaughter
Package#: 427693
Received Date: 3/19/2020
Review Start Date: 9/15/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC Quadrant Section Township Range
County AIRS ID: 123 SWSE 20 2N 64
Plant AIRS ID: 9E16
Facility Name: Dale 20H-0264 Battery
Physical
Address/Location: _. „_
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment;Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC).
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Point B Permit#
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
APCD has already Emissions Source Type Equipment Name Control? APCD has already B Required? _Action Remarks
assigned) assigned)
Permit Initial
021 Separator Venting Buffer Yes 20WE0344 1 Yes Issuance
Section 03-Description of Project
Crestone Peak Resources Operating,LLC(Crestone)submitted an application to modify an existing major well production facility located in the ozone non-
attainment area.With this application,the operator is requesting to modify the existing condensate storage vessel and produced water storage vessel sources
in addition to permitting the flaring of natural gas from the low pressure separators.Thisanalysis only evaluates the separator venting source.
This new source is APEN required because uncontrolled requested VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section 11.B.3.a.).
Additionally,the source is permit required because uncontrolled actual emissions from all.APEN required sources at this facility are greater than 2 tpy(CO AQCC
Regulation 3,Part B,Section II.D.2.a).
Public comment is required for this application because new synthetic minor limits are being established in order to avoid other requirements.
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: S02 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ Q ❑ ❑
Title V Operating Permits(OP) ❑ ❑ ❑ -D ❑ EEO
Non-Attainment New Source Review(NAN5R) ❑ lI
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 ❑ _ ❑
Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ODD
Non-Attainment New Source Review(NANSR) ❑ ❑
Separator Venting En-,isons InVeotor,/
Section 01-Administrative Information
Facility AIRS ID: 123 9E16 021-k%.
County Plant Point
Section 02-Equipment Description Details
Flaring of naturalgas vented from the l pressure side of eleven(1t)high/low pressure separators and routed through the buffer
Detailed Emissions Unit Description' house
Em anion Control Device Description. -Enclosed Combustor))during vapor recovery unit(VRU)downtime
Requested Overall VOC&HAP Control Efficiency
limited Process Parameter
Gas meter _ _�:
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput'- - MMscf per year
Requested Permit Limit Throughput-,,, ;e2Z90 MMscf per year Requested Monthly Throughput= T..: MMsd per month
Potential to Emit)PTE)Throughput= 2.5^-MMscf per year
Secondary...sins Device(s)for Air Pollution Control
... ..
Separator Gas Heating .ng Value: 2127.6 B[u/scf
Volume of waste gas emitted per BBL of
liquids throughput: __:scf/bbl
Control Device
Pilot Fuel Use Rate: 0..300 MMset/Vr
Pilot Fuel Gas Heating Value: Btu/scf 0.0 MM6tu/yr
Session 04-Emissions Factors&Methodologies
Description •
Eleven(13)wells at this facility produce to eleven(11)high/low pressure[HLP)separators.The high pressuregas from the high pressure side of the HIPseparators Is routed to the sales Ilse sta vapor recovery units.The
low pressure gas from the low pressure side of the HLP separators Is typically routed through a buffer house(liquids knockout)and then.the sales line v vapor recoveryunh.During vapor recovery..downtime,the
low pressure gas vented from the low pressure side of the HLP separators is routed through a buffer house(liquids knockout)and then turbo enclosed wmbust.r(s).Murder.develop site spedfk em'ssian factors,the
operator.btait ed a gas sample from the outlet of the buffer house on 01/16/2020.This gas sample Is representative of only low pressure gas vented from the low pressure side of the HIP zepamtors and routed through
the buffer house and then to the enclosed rombustor(s).The sample temperataee and pressure are 57 f and UE psig respectively.The molecular weight and weight%values from the sampk were used In conjunction with
the D placement Equation listed below.develop the site speclfic emission factors.
IMW ) 38.4921llb/Ib-mot Displacement Equation
Ex=41MW*Xx/C
Weight%
Oxygen/Argon 0:0228
CO2 2:]0]1
N2 0.0934
methane 1.084]
ethane 1].0569
Propane 29.0095
isobutane :.5.8312
n-butane11.2]31
isapentane4.8]02
n-pentane 5.]980
cyclnpentane 0.3669
n-Hexane 1.4294
cVcahexane .:0.3388
Other hexanea 2.3663
heptanes 0.1619
methylrydoheaane 0.2115
224-TMP 0.0001
Benzene 0.1885
Toluene 0.1116
Ethylbenzene 0.0055
Xylenes 0.0185
014 Heavies 0.3986
Total ... _
VOC Wt
Emission Factors Separator Verging
Uncontrolled Controlled Emission Factor Source
Pollutant lib/MMscf) (Ib/MMsd)
(Gas Throughput) (Gas Throughput)
VOC
Extended gas analrsk
Benzene Extended gas analysis
Toluene 1 3 - .Extended gas analysis
Ethylbevene ghttExtended gas analysis
XVlene 19) Ex nded gR.N.
n-Hexane i Extended gas analysis
2241MP I i Sad.' `)mended gas analysk
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtal Ib/MMsd Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 0.00]1ddhh 4.na AP-92.6.19-2(PM7.0/PNI.75)
P542.5 119W2 AP_42 Table 342(PM10/PM25)
SOx 00006 AP-42 Table 142[SO) •
:.
NOx 4 `.AP-42 Chapter 13.5Industrial Fl (50x)
CO .0,3100 .:v AP-42 Chapter 135 ndµtela.Flares(CO)
Pilot tight Emissions
Unoanvolled Uncontrolled
Pollutart (Ib/MMBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10
PM2.5
SOx
NOx
VOC
CO
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthy Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (wns/year) (tons/year) (tons/year) (Ibs/month)
PM10 0.024
PM2.5 U.0'I.a - 0.02k -
SOx 0.00). s'
NOx 0.115 d d idt
e SI,
VOC
CO a'hidd
Potential to Emit Actual Emissions Lima
Permit a
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) Ilbs/year) Ilbs/year) llbs/year) Ilb,/yearl
Benzene _. 'Ss
Toluene
_ -
Ethylbenzene . -
Xylene
n-Hexane P
224 TMP
2 of 4 C\Users\hslaught\Desktop\1239E36\20W E0344.CP3
Section OS-Regulatory Summary Analysis
Regulation 3,Parts A,B
Regulation?,Part D,Section!LB,F ..
Regulation 7,Part O.Section 11.8.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 02-InMO and Periodic Sampling and Testing Requirement
Using Gas Throughput to Monitor Compliance
Doe the company use site specific emission factors based on a,.sample to estimate emissions? - y^
This sample should represent the gas outlet&the equipment covered under thisAlRs 10,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 he appropriate to use an older site-specific sample
If no,the permit will tontale 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 year the ozone nonatta nment
area OR are emissions greater than or equal to 90 tons per yearn the ozone attainment area?
Wyss,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 Ibis application.
-A'pedodfcTerting Requirement-to collect a sitespecific gas sample from the equipment being permitted and conduct an emission factor analysis m demons..that the emission factors
re 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 pont?
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 aperadonal(no to exceed 180 days).
This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbi(value In section 03,
Does the company request a control dev eefficiency greater than 95%for a flare combustion decker
If yes,the permit will contain tial and periodic compliance testing in accordancewith P5 Memo20-02
M,r. D�uW ry
.
hr
r
"Si.,,,,,ia s,.f ,tn_,.a>,,k , ,;,via ,,,,,z,w.,1, ;`lea ,,, ,,,R. a e
Section 08-Technical Analysis Notes
I According to the aplicaton,eleven(11)wells produceto this fanhty.:The names and API numbers of the wells are available for reference on the condensate storage vessel APE N submitted on 03/19/2020 According to COGCC data,thee.
wells at this facility werofracturecl between December 2014 and January 2015.The wells began production In March 2015,51x(6)wells produce horn the Niobrara formation,four(4)produce from the Catlett-FsO Hays f rmatons,and
one(1)produces from the Niobrara-Codell-ForhHays formations.Sine the wells began production after 08/01/2014 the sepzrStars covered by This paint are subject to Regulation?,Parto,Section ILF.
2.The extended gas alysls used to establish emission factors In thisapplkation was obtained from the outlet of the buffer house(liquids knockout for law pressure gas vented from the low pressure side or-the HLP separators)at this
fa tlty.As a result,it is representative of only low pressure gas that is ventedto and controlled by the enclosed combustors.Additonally the sample was obtained an 91/26/2020.Since this sample is site specific and was obtained after all
the wells began producing at this'acilie,it was deemed acceptable for establishing emission factors without the need for initial sampling.It should be further noted that no new wells have been added tothe feria and the existingwelb
at the facility have not beenrefrattured sincethe samples. obtained..This further supports the removal ofrmtral sampling to tonnrre the accuracy of the emissiortfectors
3 the hydrocarbon loadout,separator noting and condensate storage vessels are controlled by the same enclosed combustors at this facility.Engineering guidance dictates dot pilot light emissions should be grouped with the highest
emitting sourcewhen sources are controlled by a common control device.In this case,the highest rig source is the condensate storage vessels.As a result,the pilot light combustion emissions are includedin the analysis far the
condensate storage vessels(see the preliminary analysis for 10WE0343.CP1).
4.Engineering guide indicates that NO4 and CO emissions horn each source controlled bye common control device need to together to evaluate APlArlieapplicability.Total CO missions from all sources at this tally that are
controlled bythe ended combustors(condensate storage verselssrolleda venting and hydrocarbonioadouuu are greater than APENlhresholds.Asa result,the permit for o source controlled by the common control device will have
tints on CO emissions.Total NOxemu onzfrom all the so es controlled by the endosedcombustors are below APEN reportingthroshalds.AsaresutL.the permtvri ill notcontain emlztion limits orem sslonhctors for NOx
5.Arcordingtathe operator,a flow reefer has not been installed at this facility.Since The source is located in the nonattainment area and uncontrolled requested emissions are greater Than 50 hay,the operator is required to instal
flow meter to measure thegas vented from the low pressure Ode of the HLP separators and routed to the enclosed combustors to demonstrate ongoingcomplfance.Up until the flow meters Installed,the operator will be required to use
thethOR developed from the ProMaesmulatian(38.2 in conjunction withthe monitored condensate throughput routed to the storage vessels to demonstrate ongoing complianrewith the permit'Menermit will require Mettle
flora meter Is'nailed such that It only measures the low pressure separator gas vented from the low pressure side of The HLP separators and routed through the huffier houseio the ecalosed combustors.
6 During normalop r f its,low pressure gas Vented fromthe low pressure side of the HLP separators Is captured usingvapor recovery units(VRUs)and muted to Me sales line.During VRU do ntme,the low pressure gas is routed
through the buffer house(liquids knockout)and then to the enclosed combustors.The Row meter will he installed downstream of the 000 such that It only measures the volume of IOW pressure pas routed I.the enclosed combuomr(s).
As a result,VRU downtime tracking W11nnot he required in the permit.verify the volume of gas vented tom the separators and routedto the encased rombustar(s)..
T.Initial and pedodic visible emissions checks for.the control deviceareaddressed by the O&M pi n,As a result,the pererhdoes not Contain initial or periodic opactytesting
B.Benzene,toluene and n Hexane are the only reportable HAPs(I e.>250 lb/year).As a result,they are the only HAPs for witch emission factors are Included in the permit.
9.The operator Was provided with a draft permit and APES redline to review p to public comment The operator reviewed both documents and expressed they had no comment.
v:.
Section On-SCC Coding and Emissions Factors(Far Inventory Use Only)
AIRS Point,' Process SCC Code Pollutant Uncontrolled Emissions Factor Control% Unts
021 01 PLATO
PMR,5 in;
5O4
NO4
VOC
Co S?5.1
Benzene 191.5
Toluene 1133
Ethylbenzene `l.B fhlM5LuCF
Oefene 185 + LO/MM5lF
n-Hexane 1446.' _ u.ININrcr
224 TMP 0.7 Uu y/§rMBtb
•
•
3 aft C:\Users\hslaueht\Oesktop\1239E16\20WEo344.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
Sun r<..m�is Iii the Ndn.11ttumrnevt Apia
-'ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1a)?
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.0.3)?
'You have indicated that source is in the Note/attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section II.D.1.a)? Yes Source Requires en APEN.Go to the next question
2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part 0,Section 11.0.2)? Yes Source Requires a permit
'Source require,a permit
Colorado Regulation 7,Part O,Section II
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? 'Yes:; -'Source is subject,go to next question
ISouicn rs sublebt to Regulation 7,Part I),Section{1.11.2,7
Section II.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II
Section II.F-Control of emissions from well production facilities
Alternative Emissions Control(Optional Section),
a. Is this separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? , .It., The control device for this separator is not subject to Regulation 7,Section XVII.B.2.e
,;?vi'c'e for this separator is not subject to Regulation 1,Part U,Sebtton
Section II.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is
note rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,
regulation,or any other legally binding requirement and is 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"ban,"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
MAR l 9 2020
Condensate Storage Tank(s) APEINAr
•� Form APCD-205
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 2_0lAjEC3L1' AIRS ID Number: 123 / 9E16 /001
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Dale 20H-O264 Battery
Site Location
Site Location:
SWSE Section 20, T2N, R64W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10188 East 1-25 Frontage Road
Firestone, CO 80504 Contact Person: Sabrina Pryor
Phone Number: (303) 774-3923
E-Mail Address2: sabrina.pryor@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
427689
COLORADO
rwene
r^: PC D-705 (';^.. _ ?!'_ ti,_ _ 1_ :.;i, r:ptl'1 ttP Ji ICiI 12 ll`?,.l 1ili alas..+
Page 5 of 85
Permit Number: 20WE0343 AIRS ID Number: 123 /9E16/001
Section 2 - Requested Action
0 NEW permit OR newly-reported emission source
O Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 0 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 0 Change company name3
❑ Change permit limit ❑ Transfer of ownership' 0 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: Requesting source be converted from a GP01 to a
traditional construction permit.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate storage tanks
Company equipment Identification No. (optional): TANKS
For existing sources, operation began on: 3/8/2015
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: 0 Exploration Et Production (E&P)site 0 Midstream or Downstream (non E&P)site
Wilt this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes 0 No
Are Flash Emissions anticipated from these storage tanks? ❑✓ Yes 0 No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? 0 Yes 0 No
If"yes", identify the stock tank gas-to-oil ratio: m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes 0 No
805 series rules? If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual ® Yes 8 No
emissions≥6 ton/yr(per storage tank)?
COLORADO
P ia.L S - Cc - _.'.o-� T3. :cis . PE'i �_VISt'�"' i2'2.:'; 2 I 'rev�"....
Page 6 of 85 Redlines per email. (HDS 10/15/2020)
Permit Number: 20WE0343 AIRS ID Number: 123 /9E16/001
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 48,307 74,460
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 44.9 degrees RVP of sales oil: 10.7
Tank design: ❑✓ Fixed roof ❑ Internal floating roof O External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TANKS 10 5,000 3/2015 3/2015
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 39738 Dale 4A-20H-O264 ❑
05 - 123 - 39724 Dale 4B-20H-O264 ❑
05 - 123 - 39728 Dale 4C-20H-O264 ❑
05 - 123 - 39730 Dale 4D-20H-O264 O
05 - 123 - 39723 Dale 4E-20H-O264 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)
40.122582/-104.574498
Ei 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)
o Upward ❑Downward O Upward with obstructing raincap
o Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width (inches): Interior stack depth (inches):
o Other(describe):
COLORADO
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Page 7 of 85
Permit Number: 20WE0343 AIRS ID Number: 123 /9E16/001
Jr-'! , P`r°; E _ 'mod' , ,,...,., _ ' -_
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
0 Recovery
Unit (VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
Pollutants Controlled: VOCs, HAPs
Rating: NA MMBtu/hr
Type: Enclosed Combustor Make/Model: NA
❑✓ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
2537.1
Minimum Temperature: NA Waste Gas Heat Content: 2,587 Btu/scf
Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating: 0.025 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
0 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)? 40 psig
Describe the separation process between the well and the storage tanks: Wellhead production to
high-low pressure three-phase separators, high-pressure gas to sales, low-pressure gas to
enclosed combustor. Condensate and produced water to storage tank battery.
Redlines per email. (HDS 10/15/2020)
COLORADO
AP CD-L'5 rC'_ •a...},� S':()! a Tan1,:. ADD!' - '{_ 12'2:1;
4 I - !x.ni 'renw.+
Page 8 of 85
r
I
Permit Number: 20WE0343 AIRS ID Number: 123 /9E16/001
p..,.....,:-≥l .- E-4 . .._ -. _.
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? ❑� 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 (%reduction of captured
by control equipment) emissions)
VOC Enclosed Combustor(ECO) 100% 95%
NOx
CO
HAPs Enclosed Combustor(ECD) 100% 95%
Other:
From what year is the following reported actual annual emissions data? 201 9
Use the following table to report the criteria pollutant emissions from source:
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions
Basis Mfg.,etc.)
(tons/year) (tons/year) (tons/year) (tons/year)
VOC 8.61 lb/bbi Site Specific 136.87 6.84 320.56 16.03
NO,, 0.068 lb/MMBtu AP-42 0 21 0 21 0.59 0.59
CO 0.31 Ib/MMetu AP-42 0.97 0.97 2.69 2.69
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable, and should consider
future process growth. Requested values are required on all APEN5, including APEN updates.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEi Yes ❑ No
pollutants (e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Abstract Source Uncontrolled Controlled
Chemical Name Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions8
Number Basis Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 251E-02 lb/bbl Site Specific 681 34 •
Toluene 108883 1.88E-02 Ib/bbl Site Specific 594 30
Ethylbenzene 100414 1 35E-03 lb/bbl Site Specific 97 5
Xylene 1330207 6.11E-C3 lb/bbl Site Specific 459 23
n-Hexane 110543 1.71E-01 lb/bbl Site Specific 7,773 389
•
2,2,4-Trimethylpentane 540841 4.74E-04 Iblbbl Site Specific 324 16
Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site •
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Redlines per email. (HDS 10/15/2020)
COLORADO
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Page 9 of 85
I
Permit Number: 20WE0343 AIRS ID Number: 123 19E16/001
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
� � l 03/16/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sabrina M. Pryor Air Quality Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
Or 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
laii --,,.COLORADO
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Page 10 of 85
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name: Crestone Peak Resources Operating, LLC
Source Name: Dale 20H-O264-Condensate Tanks
Emissions Source AIRS ID2: 123/9E16/001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05- 123-39731 Dale 4F-20H-O264 ❑
05- 123-39726 Dale 4G-20H-O264 ❑
05- 123-39725 Dale 4H-20H-O264 ❑
05-123-39727 Dale 41-20H-O264 ❑
05- 123-39729 Dale 4J-20H-O264 ❑
05- 123-39733 Dale 4K-20H-O264 ❑
- - ❑
- - ❑
- - ❑
- - ❑
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
ii
III
Form APCD-212 B2-APEN FORM 212-TANKS- Wellsite Addendum
Page 11 of 85
r 9 2020
Gas Venting APEN - Form APCD-2 ~p
LAI
Air Pollutant Emission Notice (APEN) and
C0PHE Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 2-0 WE 031.ht AIRS ID Number: 123 / 9E16 / 22 J
[L_a e r;ess. ! M1I. i
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Dale 20H-O264 Battery
Site Location: SWSE Section 20, T2N, R64W Site Location Weld
County:
NAICS or SIC Code: 1311
Mailing Address: 10188 East 1-25 Fronts a Road
(Include Zip Code) g
Firestone, CO 80504 Contact Person: Sabrina Pryor
Phone Number: (303) 774-3923
E-Mail Address2: sabrina.pryor@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
427691
COLORADO
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Page 19 of 85
Permit Number: 20WE0344 AIRS ID Number: 123 /9E16/ 021
Section 2 - Requested Action
❑✓ NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit(check eoch box below that applies)
❑ Change fuel or equipment 0 Change company name3 0 Add point to existing permit
❑ Change permit limit 0 Transfer of ownership4 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS-
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Buffer(separator)gas venting controlled by enclosed combustor
Company equipment Identification No. (optional): Buffer
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is: 4/1/2020
Ei Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS YesNo
nonattainment area? ❑ 0
Is this equipment located at a stationary source that is ❑ Yes Q No
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7, Yes 0 No
Section XVII.G?
COLORADO
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Page 20 of 85
Permit Number: 20WE0344 AIRS ID Number: 123 /9E16/ 021
a,
Section 4 - Process Equipment Information
0 Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial #: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator,you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes 0 No
Vent Gas 2177.6 BTU/SCF
Gas Venting Heating Value:
Process Parameters5:
Requested: 2.9 MMSCF/year Actual: MMSCF/year
-OR-
Liquid Throughput Requested: 74 460 bbl/year — bbl/year Parameters5: Actual: _ bbl/ ear
Molecular Weight: 38.49
VOC (Weight%) 69.0352
Benzene (Weight%) 0.1885
Vented Gas Toluene (Weight%) 0.1116
Properties: Ethylbenzene(Weight%) 0.0055
Xylene (Weight%) 0.0185
n-Hexane (Weight%) 1.4244
2,2,4-Trimethylpentane (Weight%) 0.0007
Additional Required Documentation:
❑ Attach a representative gas analysis (including BTEX Et n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis (including BTEX Ft n-Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
�jICOIOR ADO
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Page21 of85 Redlines per email. (HDS 10/15/2020)
Permit Number: 20WE0344 AIRS ID Number: 123 /9E16/ 021
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.122582/-104.574498
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Discharge Height
Operator Temp. Flow Rate Velocity
Above Ground Level
Stack ID No. ('F) (ACFM) (ft/sec)
(Feet)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ 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):
Section 6 - Control Device Information
o Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency: %
VRU Downtime or Bypassed:
Pollutants Controlled: VOCs, HAPs
Rating: NA MMBtu/hr
Type: Enclosed Combustor Make/Model: N/A
❑
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 95
Minimum Temperature: NA Waste Gas Heat Content: 2,178 Btu/scf
Constant Pilot Light: ❑ Yes O No Pilot burner Rating: 0.025 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
P^� i r — r., leo-cOIORADO
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Page 22 of 85
Permit Number: 20WE0344 AIRS ID Number: 1 23 /9E16/ 021
7,L„„,2,„
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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 ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined,values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
Sox
NO.
CO
VOC Enclosed Combustor 100% 95%
HAPs Enclosed Combustor 100% 95%
Other:
From what year is the following reported actual annual emissions data? NA
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant ' Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions6 Emissions Emissions
Basis Mfg.,etc.)
(tons/year) (tons/year) (tons/year) (tons/year)
PM
SOx
NO. 0.068 Ib/MMBtu AP-42 NA NA 0.22 0.22
CO 0.31 Ib/MMetu AP-42 NA z NA 0 98 0.98
VOC 70.114 Ib/MMscf Site specific NA NA 101.67 5.08
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth.Requested values are required on all APENs,including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide
projected emissions.
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑ No
pollutants (e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service (CAS) Basis Units (AP-42, Emissions , Emissions6
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 191.44 Ib/MMscf Site specific 555.2 27.8
Toluene 108883 113 34 lb/MMscf Site specific 328.7 16.4
Ethylbenzene 100414 5.59 Ib/MMscf Site specific
Xylene 1330207 18 79 Ib/MMscf Site specific
n-Hexane 110543 1446.65 IbIMMscf Ste specific 4,195.3 209.8
2,2,4-Trimethylpentane 540841 0 71 tb/MMsd Site specific
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
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Page 23 of 85 Redlines per email. (HDS 10/15/2020)
Permit Number: 20WE0344 AIRS ID Number: 123 /9E16/ 021
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct^
f 03/16/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sabrina M. Pryor Air Quality Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
1✓ 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
APCD-SS-B1 OR
4300 Cherry Creek Drive South (303) 692-3148
Denver, CO 80246-1530
APCD Main Phone Number
Make check payable to: (303)692-3150
Colorado Department of Public Health and Environment
COIORAOO
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y,_.,Sv 6 I w.ws�..�..
Page 24 of 85
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