HomeMy WebLinkAbout20203642.tiff : COLORADO
Department of Public
- Health&Environment
RECEIVED
NOV 3 0 2020
WELD COUNTY
Weld County - Clerk to the Board COMMISSIONERS
1150O St
PO Box 758
Greeley, CO 80632
November 23, 2020
Dear Sir or Madam:
On November 24, 2020, the Air Pollution Control Division wilt begin a 30-day public notice period for
Crestone Peak Resources Operating, LLC - Echeverria 2H-D267. 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 &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
764 ,
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe r`g �,
Jared Polls,Governor I Jilt Hunsaker Ryan,MPH, Executive Director ;,4 t---,‘- ,,.1
Pub I:c Rev:e t,J CC:PL(7P)-lL(DS)Pw(5 t/E2/c-f/c 2020-3642
t2 I -/2a 06 Cam)
12-1091.20
.:,-CAir Pollution Control Division
` C " Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Crestone Peak Resources Operating, LLC - Echeverria 2H-D267 - 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: Echeverria 2H-D267
Well production facility
NWNW Section 2 T2N R67W
Weld County
The proposed project or activity is as follows: Applicant requests to modify an existing well production
facility located within the ozone nonattainment area. With this application, the operator is requesting to
permit the flaring of natural gas from the low pressure separators. The application brings the facility to
synthetic minor status for NANSR and Title V for VOC (under 50 tpy).
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 20WE0565 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:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
A24. COLORADO
. Department of Public
1 I corrte Health 6 Environment
f»1K- COLORADO
Air Pollution Control Division
COPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
•
CONSTRUCTION PERMIT
Permit number: 20WE0565 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Echeverria 2H-D267 Battery
Plant AIRS ID: 123/A043
Physical Location: NWNW Section 2 T2N R67W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
ID Point Equipment Description Description
Flaring of natural gas vented from the low
pressure side of twelve (12) high/low Enclosed
Buffer 012 pressure (HLP) separators and routed
through the buffer house during vapor Combustor(s)
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
littps://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self-
Page 1 of 11
COLORADO
40 444-411 Air Pollution Control Division
C'
COPHE E Department of Public Wealth&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must 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
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO VOC CO Type
X
Buffer 012 --- --- 9.8 --- Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year,
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
6. 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
Page 2 of 11
CCOLORADO
IMP Air Pollution Control Division
cDPHC
Department of Public Health&Envtronment
Dedicated to protecting and improving the health and environment of the people of Colorado
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
7. 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 Pollutants
ID Point Control Device Controlled
Emissions from the low pressure side of
twelve (12) high/low pressure (HLP)
Buffer 012 separators are routed through the buffer VOC and HAP
house to enclosed combustor(s) during
vapor recovery unit (VRU) downtime.
PROCESS LIMITATIONS AND RECORDS
8. 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 Parameter Annual Limit
Point
Buffer 012 Natural gas venting 4.40 MMSCF
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.
9. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the separator(s) using the 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.
Page 3 of 11
COLORADO
Air Pollution Control Division
cafl+E Department of Public I leatth b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
13. The 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.
14. 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 Ft MAINTENANCE REQUIREMENTS
15. 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.)
Page 4 of 11
% COLORADO
Air Pollution Control Division
Department of Public Health fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section I I.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
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
Page 5 of 11
C *W COLORADO
Air Pollution Control Division
OP
Department Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
19. 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
Current
Permit
AIRS Equipment Pollutant Limit
Point Description Threshold (permit-
required
points
only)
001 Condensate tanks
002 Produced water tanks
003 Condensate loadout
004 Compressco GJ230
(permit-exempt)
005 Compressco GJ230 VOC 50 39.8
(permit-exempt) NOx 50 1.9
006 Compressco GJ230
(permit-exempt)
012 Separator Venting
Insignificant Sources
(APEN- and/or
permit-exempt)
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
20. 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
COLORADO
Air Pollution Control Division
CDPH
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
21. 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.
22. 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.
23. 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.
24. 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.
25. 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.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Page 7 of 11
COLORADO
4• Air Pollution Control Division
COPHE
Department of Public Heath&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By:
Andy Gruel, P.E.
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
»vz- COLORADO
41 '1 Air Pollution Control Division
COPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment AIRS Uncontrolled Controlled
ID Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 1557.69 77.88
Toluene 108883 1433.87 71.69
Ethylbenzene 100414 51.79 2.59
Buffer 012 Xylenes 1330207 294.89 14.74
n-Hexane 110543 13491.98 674.60
2,2,4-
540841 6.60 0.33
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
-»_#:(��r� COLORADO
Air Pollution Control Division
COPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 012:
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/MMSCF) (lb/MMSCF)
NOx 166.0764 166.0764 AP-42 Ch. 13.5
CO 757.1130 757.1130 AP-42 Ch. 13.5
VOC 89067.15 4453.3575
71432 Benzene 354.02 17.701
108883 Toluene 325.88 16.294 Site-specific gas
100414 Ethylbenzene 11.77 0.589 analysis collected
1330207 Xylenes 67.02 3.351 8/5/2019
110543 n-Hexane 3066.36 153.318
540841 2,2,4-Trimethylpentane 1.50 0.075
Note: The controlled emissions factors for this point are based on the enclosed combustor control
efficiency of 95%. The VOC and HAP emission factors listed above are based on a site specific
extended gas analysis collected 8/5/19. The weight%values and molecular weight (43.7194
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.
NOx and CO emissions are based on a gas heat value of 2442.3 Btu/scf, and are below the APEN
reporting threshold. Actual emissions are calculated by multiplying the emission factors in the
table above by the total throughput of gas as measured by the flow meter.
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, HAPs (total, and n-hexane)
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.aov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
Page 10 of 11
». COLORADO
Air Pollution Control Division
[O?NE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Andy Gruel ..
Package#: 431746
Received Date: 5/28/2020
Review Start Date: 11/18/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC Quadrant Section Township Range
County AIRS ID: 123 NWNW 2 2N 67
Plant AIRS ID: A043
Facility Name: Echeverria 2H-D267 Battery .. .
Physical
Address/Location:
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment7Oil&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 if Permit If
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
APCD has already Emissions Source Type Equipment Name Control? APCD has already 6 Required? Action Remarks
assigned) assigned)
Permit Initial
012 Separator Venting Buffer Yes 20WE0565 1 Yes ''Issuance
Section 03-Description of Project
Crestone Peak Resources Operating,LLC(Crestone)submitted an application to modify a well production facility located in the ozone non-attainment area
With this application,the operator is requesting to permit the flaring of natural gas from the low pressure separators.The application brings the facility to
synthetic minor status for Title V for VOC(under 50 tpy).
Public comment is required for this application because the permit establishes a new synthetic minor limit on VOC below 50 tpy and the NANSR threshold.
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 new syn minor limit for VOC for NANSR
Section 05-Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ ❑ El ❑ ❑ ❑
Title V Operating Permits(OP) ❑ ❑ ❑ O ❑ ❑ ❑ O
Non-Attainment New Source Review(NANSR) ❑ 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) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑
Non-Attainment New Source Review(NANSR) ❑ ❑
Se�d•ato v..:.,.,
Section 01-Adminlstretive Information
IFacifiry Ales ID: 123' 0043 Pointt1
County Plant
Section 02-Equipment Description Details
Detailed Emissions unit Description: Flaring of natural gas ventedfromthe low pressure side of twelve(12)high/low pressure separators and routed through the buffer house.
Emission Control Device Description: Enclosed Combustor(s)during vapor recovery unit(VRU)downtime
Requested Overall VOC&HAP Control Efficiency%: 85
Limited Process Parameter ,. �_r.t'l�`• :. n .�
Gas to -y+• '�
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= k MMscf per year
Requested Permit Limit Throughpst= .4.4 MMscf per year Requested Monthly Throughput= MMs f per month
Potential to EmO(PTE)Throughput= 4.4 MMscf per year
Secondary Emissions-Combustion Device(s)forAir Pollution Control
Separator Gas Heating Value: 24423 Btu/scr tram site specific gas sample collected 8/5/15
Control Device
Pilot Fuel Use Rate: 25 son, .r MMscf/yr
Pilot Fuel Gas Heating Value: 10008tu/scf 219.:MMBtu/yr
Section 04-Emissions Factors&Methodologies
Description
The wells at this facility produce'.twelve(12)high/low pressure Mtn)separators.The high p ure gas from the high pressure side of the HP separators Is r000ed;thesales line vlavaporecovery units.The low pressure
gas from the low pressure side of the Hi,separators Is ryplcally routed through a buffer house liquids knockout)and then to the sales Roe via vapor-recovery units.During vapor recovery bole 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 to the enclosed combusteds)Aflow meter shall be used to track actual volume of emissions,end a site-
specific extended gas analysis collected e/5(19 was used to develop lb/MMscf emission factors.Due to rounding,my calculated emission factors differed slightly from those presented by the applicant,and I accept those
presented by the applicant.
Molecular weight
Weight%
Oxygen/Argon 0.4353
CO2 - 3.2856
N2 - 1:6500
methane 6.8468
ethane 12.5707
propane "24.5323
isaborate '6.5903
n-butane -- . 19.2025
Bopentane 6.7098
n-pentane 0.3904
ryclopentane 0.4517
n-Hexane 2.6582
cyclohexane 0.6538
Other hexanes 4.1002
heptanes 1.5447
methylryulohexane 0.6010
224-TMP 0.0013
Benzene 0.3069
Toluene 0.2024
Ethylbenzene 0.0102
Xylenes 0.0581
CB+Heavies 1.1105
Total
VOC Wt b
Emission Factors Separator Venting
Uncontrolled Controlled Emission Factor Source
Pollutant (Ib/MMscf) (lb/MMscf)
(Gas Throughput) (Gas Throughput) cal'duncantr.EFO(lb/MMscf)
VOL .. ,Extended g IV A m 8906736
Benzene ',Wended,analysis - 354.02
Toluene l.r.r Extended g IY 325.75
Ethylbenxene a:EMtended gas ena(yss
Xylene <wended
n-Hexane 3,6 A, ftste d d gas analysis 3066.36
224 IMP - -Extentletl gas anaiyzs LSO
0 Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source
(Waste Heai
Co
mbusted) (Gas Throughput)
PM. 0.0075 77.42 Table 1.4-2(PMIO/PM.2.5)
PM25 0:0075 SP-42 Table 1.4-2(P3410/Pm 2-51
sox 0.000E FP a2 Table 34z{5031
NOx .-0.0680 AP-439ryger 13.5 I d it l Flares(NOx)
C0 AP Rt 13 5lndustri flares(CO) ,2'
Pilaf Light Emissions
Uncontrolled Uncontrolled
Pollutant (ib/MMBtu) Ib/MMscf Emission Factor Source
(Waste Heat
Combated) (Pilot Gas Throughput)
PM10
'
PM2.5 0.0075 /4't 3)
sax 0.0006 , —T3 420 hie:},SOX
NOX 0.0680 er 1351ndustryiFieres(NOx)
VOC 0:0054 k -42 Table 1.4-2(VOC)
CO 03100 .,oa AP-47:5.6pter13.5 Indust,Pares(CO) ,;7—
7 of 5 K:\PA\2020\2tW E0565.CP1
_
•
1_ Separator Verting Emissions Invert0ory
1
1.
Section 05 Emisslons inventory
Potential to Emo Actual Emissions Requested Permit Limits Requested Monthly Limns
Cntena Pollutants Uncontro0ed Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/Year) (tons/year) Imnehear) Itons/yead Ole/month)
PM10 Pm 001 o 061 7
PM35 0(11 0 C 0 011
5Ox 0049 0Cn3 0 003
NOR 03 9 0 lx L 73 ' r
VOC 15.3 39 ou 979a 1..
CO 700 1 F9 1100 1>J
P ential to Otto Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Its/Yeas) (lb/10 I Ili he 1 - IM/par) Ilbs/tnarl
Benzene 1 /L 557 0 77 84
Toluene 1433.81 14 R..7 1109
Ethylbenzene 1 79 I l9 2 9
ey)ene 00499 2.A.a0 1174
n Hexene Is 1"8 Ise 5.s 0,no /
224TMP LAO 0.ii9 933
Section 06 Regulatory Summary Analysis ,—
Regulation 3 Parts B p Ce 1
Ragulation7 PartO section lIB F Ch)c'o cgul tun? a n1110 F
Regulation?Part Section i102e 1...co tr0lac4.c,Ill p.,at.,unot sub coteP mission e't0,cion11 CO
(see regulatory applicability worksheet for detailed analysis)
5ectlon 07 Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance :clDoes the company use site specdic emission factors based on a gas sample to estimate emissions, r I T
This sample should represent the gas outlet of the equipment covered under this AIRS ID and should have been colleted within one year of the application received date However if the fanlrty has not
been modified(e g no new wells brought on line)then it may be appropriate to use an older site-specific sample
if no the permit will contain an Initial Testing Requirement to collect a utespeDhc..sample from theequipment being permitted and conduct an emhsi0n factor analyse to demonstrate thatthe
emission factors are less than or equal to the emissions factors established with this application ffee
�y Are facility wide permuted emissions At VOC greaterthan or equal to 40 tons per year in the ozone nanattainment area ..t bhr
OR are emissions greater than or equal to 90 tons per in the ozone attainment area]
11 yes the permit will contain •
An'natal Testing Requirement"to collect a site spmfic gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less
than or equal to the emissions factors established with this application
A Periodic Testing Requirement to collect a see s pectic gas sample from the equipment being permuted and conduct an emission factor analysis to demonstrate that the emission factors are less
than or equal to the emissions factors established with this application on an annual bass
Will the operator have a meter installed and operational upon startup of this point] r
If no the permit will contain a condition that requires he operator to calculate gas throughput using the liquid throughput until the meter s installed and operational(not to exceed 180 days)ThA
condition will use the Volume of waste gas emitted per BBL of liquids throughput(sit/bbl)value In section 03
Does the company request a control device efficiency greater than 95%fore flare or combustion device] ' 70`�
If yes the perme will contain Initial and periodic compliance testing In accordance with PS Memo 20-01 ,
Section 08 Technical Analysts Notes __ 0
t1 Thewete began producing in 3019 and so the separators are subiect[o Regulation 7PaeD Sections 11 B2 and II a..� 7 y r 'c �g fa i r' z
V )
„2 The extended gas analyse used to establish emhsion m factors the application was obtained(torn a theoutiet of the buffer hge(Iiquids kno`Qoutfor low or...gas vented from the loespressure side ofthe HLP separators 7)et this faolrty As
aresult It s representative of only low pressure gas thatb vented to and controlled by the enclosed combustors ' j , /
3NOk and CO emissions from this source are below APEN reporting thresholds As aresult limits andernesion factors are not included in the permit forNmr nor CO O I/ I ' ^y )
it i 1 P 0 ,- 0 0 r - 0 (
During normal operations low prmspre gas vented from the low pressure side of theHLP separators s captured using vapor recovery units(VRUs)and muted to thesalas line Dunng VRU downtime the lac pressuregasrs routed through the a
bufferhouseQigmds knockout)and then to the enclosed combustors VRUdowetlmerracking is regmred inthepnne to quantity the volume of gas vented from the separators and routedto theenclosedoomdstor(s)
3 77
'S.Irate ondperlodM visible emissions checks for the control device are addressed by the O&M plan As aresuit the permit does not contain initial orpe0odic opacity testing 1 s
I r 'ri7 a s . r , ,
Y-
06 We te.rounding,mysuIcuIated emission factorsdRNe2d slightlyfront thcse presented by the applicant and)accept thosepresemed bytheapplicent on the APEN '
Sectlon 09 KC Coding and Emisslons Factors(For Inventory Use Only) -
.. A1t5 Point 0 Process. SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
011 01 3 0 001 GOO-Inr- PM10 18 97 0 b/pief CF
PM35 i 0] 'h/t NI _
5Ox t 17 0 h/t t el O
NO: ]Y R b/M1110Cr
VOC tOt IS a5 bite 1S F
CO 1.,1 11 0 b/dh1 CF
Benzene bl oN1-CF
Toluene 52 Al /ra t1SCl
Ethylbenzene I/7 s` vied 1 rr
- gylene J 0702 b,n,for
n Hexane sr bp,tw
224 TMP 1 0
\ 95 h/t Is
(
\
/0
I
1
/
/
3 015 N\PA\3020\30WE0565 CP1
COLORADO DEPARTMENT OF PUBLIC.HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123 History File Edit Date 11/18/2020
Plant AIRS ID A043 Ozone Status Non-Attainment
Facility Name Echeverria 2H-D267 Battery
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H25 5O2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 61.8 988.8 0.7 74.6 49.4 0.0 0.0 0.0. . 0.0 10.6 62.3 0.7 22.6 3.0 Previous taken fmm April 2019 tab
Previous Permitted Facility total 0.0 0.0 0.0 0.0 _ 1.5 985.5 0.0 6.7 48.8 0.0 0.0 0.0 0.0 1.5 59.0 0.0 6.7 2.4
001 GP01 Eight(8)500 bbl Condensate Tanks 1.2 779.4 5.3 36.4 1.2 10.0 5.3 1:8 May 2020: adjusted controlled limit down to 10
002 GP05 Two(2)500 bbl Produced Water Tanks 0.1 95.6 0.5 10.6 0.1 10.0 0.5 0.5 no change
003 GP07 Truck Loadout 0.2 110.5 0.9 1.9 , 0.2 10.0 0.9 0.1 no change
004 19WE0439.XP COMP-1: Compressco GJ230 7.3 0.4 8.3 0.1 0.9 0.4 1.8 0.1 no change
005 19WE0440.XP COMP-2: Compressco GJ230 7.3 '0.4 8.3 0.1 0.9 0.4_ 1.8 j 0.1 no change
006 19WE0441.XP COMP-3: Compressco GJ230 7.3 0.4 8.3 0.1 0.9 0.4 1.8 0.1 no change
007 Cancelled COMP-4: Compressco GJ230 0.1 0.1 Cancelled 5/28/20--removed from site
008 Cancelled COMP-5: Compressco GJ230 0.1 0.1 Cancelled 5/28/20--removed from site
009 Cancelled COMP-6: Compressco GJ230 0.1 0.1 Cancelled 52820--removed from site
010 Cancelled COMP-7:.Compressco GJ230 0.1 0.1 Cancelled 52820--removed from site
011 Cancelled COMP-8: Compressco GJ230 0.1 _ 0.1 Cancelled 52820--removed from site.:.-.
012 200/00565 Separator venting'Buffer" 0.0 0.0 _ 0.0 0.4 195.9 1.7 8.4 0.0 0.0 0.0 0.4 9.8 1.7 0.4 May 2020. new point
0.0 0.0
0.0 0.0
0.0 0,0
0.0 0.0
ADEN Exempt/Insignificants 0.0 0.0
XA Fugitives 1.0 0.1 1.0 0.1 From May 2020 Form 102
XA Hi/Low Separators 0.2 0.2 2.4 0.1 2.0 0.0 0.2 0.2 2.4 0.1 - 2.0 0.0 From May 2020 Form 102
XA Bulk Heater Treater 0.1 0.1 0.8, 0.6 0.0 0.1 0.1 , 0.8 0.6 0.0 From May 2020 Form 102
0,0 0.0
0.0 0.0
0.0 _ 0.0
FACILITY TOTAL 0.3 0.3 0.0 0.0 27.0 1,182.7 1.0 35.9 57.9 0.3 0.3 0.0 0.0 7.8 41.1 1.0 16.4 3.5 VOC: Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
CO: True Minor(PSD and OP)
HAPS: Syn Minor n-Hex&Total
•
Permitted Facility Total 0.0 0.0 0.0 0.0 1.9 1,181.4 0.0 8.4 57.2 0.0 0.0 0.0 0.0 1.9 39.8 0.0 8.4 2.9 Excludes units exempt from permits/APENs
(4)Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.4 -19.2 0.0 1.7 Pubcom required based on new syn minor limit for
VOC for NANSR
Total VOC Facility Emissions(point and fugitive) 42.1 Facility is eligible for OP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -19.2 Project emissions less than 25150 tpy
Note 1
Note 2
Page 4 of 5 Printed 11/19/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Creston Peak Resources Operating,LLC
County AIRS ID 123
Plant AIRS ID A043
Facility Name Eckeverria 2H..EMk7 Battery
Emissions-uncontrolled(Ibs per year)
POINT'PERMIT I Description— Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethyl benzene Xylenes n-Hexane MeOH 224TMP H2S TOTAL
(tPY)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 GP01 Eight(8)500 bbl Condensate Tanks 5520 6439 311 2405 57811 . 222 36.4
002 GP05 Two(2)500 bbl Produced Water Tanks 5110 16060 10,6
003 GP07 Truck Loadout 384 3370 1.9
_
004 19WE0439.XP COMP-1:Compressco GJ230 39 12 11 7 2 0 'I 33 0,1
005 19WE0440.XP COMP-2:Compressco GJ230 89 12 '11 7 2 0 1 13 0.1_
006 19WE0441.XP COMP-3:Compressco 02230 89 12 11 7 2 0 1 13 0.1
007 Cancelled COMP-4:Compressco GJ230' 89 '12 11 7 2 0 1 13 0.1
008 Cancelled COMP-5:Compressco GJ230 89 12 '11 7 2 0 1 '13 0.1
009 Cancelled COMP-6:Compressco GJ230 89 12 11 7 2 0 'I 13 0.1
010 Cancelled COMP-7:Compressco 02230 88 12 11 7 2 0 1 13 0.1
011 Cancelled COMP-8:Compressco GJ230 89 12 111 7 2 0 1 13 0.1
012 20WE0565 Separator venting"Buffer" 1558 1434 52 295 13492 7 8.4
0.0
0.0
0.0
0.0
APEN Exemptllnsignificants 0.0
XA Fugitives 7 19 2 20 55 1 0.1
XA Hi/Low Separators 4 87 0.0
XA Bulk Heater Treater- 1 211 0.0
0.0
0.0
0.0
TOTAL gay) 0.4 0.0 0.0 _ 6.3 4.0 0.2 1.4 45.5 0.1 0.1 0.0 0.0 57.9
`Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text:uncontrolled emissions de minimus
Emissions with controls(lbs per year)
POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224 TMP H2S TOTAL
Itcy)
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 GP01 Eight(8)500 bbl Condensate Tanks 276 322 16 120 2891 11 1.8
002 GP05 Two(2)500 bbl Produced Water Tanks 256 803 0.5
003 GP07 Truck Loadout 19 169 0.1
004 19WE0439.XP COMP-1:Compressco GJ230 89 12 11 7 2 5 1 13 0.1
005 19WE0440.XP COMP-2:Compressco GJ230 89 12 11 1 2 0 'I '18 0.1
006 19WE0441.XP COMP-3:Compressco GJ230 89 12 11 7 2 0 13 0.1
007 Cancelled COMP-4:Compressco GJ230 89_ ' 12 11 7 2 0 13 0.1
008 Cancelled COMP-5:Compressco GJ230 89 /2 11 7 2 0 13 0.1
009 Cancelled COMP-6:Compressco GJ230 89 12 11 7 2 0 13 0.1
010 Cancelled COMP-7:Compressco GJ230 59 12 11 7 2 0 13 0.1
011 Cancelled COMP-8:Compressco GJ230 80 12 11 7 2 0 13 0.1
012 20WE0565 Separator venting"Buffer" 18 72 3 18 675 0 0.4
0.0
0.0
0.0
0.0
APEN Exempt/I nsigniflcants 0.0
XA Fugitives 7 19 2 20 55 1 0.1
XA Hi/Low Separators 4 57 0.0
XA Bulk Heater Treater 1 28 0.0
0.0
0.0
0.0
TOTAL(tpy) 0.4 0.0 0.0 0.3 0.2 0.0 0.1 2.4 0.1 0.0 0.0 0.0 3.5
5 20W E0565.CP1 11/19/2020
t mtai
Gas Venting APEN - Form APCD-211
C 4'44- • 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: 24 vvt °s us AIRS ID Number: 123 /A043/ C l
Re.1Ve rl� !�r;i .,..� n z .,� crE a Ga r _ µti ID
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Echeverria 2H-D267 Battery
Site Location
Site Location: NWNW Section 2, T2N, R67W Weld
County:
NAICS or SIC Code: 1311
Mailing address: 10188 East 125 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
' 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.
431744
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 12'2019 1
Page 5 of 37
Permit Number: AIRS ID Number: 123 /A043/
A PCB has d!re 3., assigred a pi:-?!rnt _o c1 AIRS iDi
Section 2 - Requested Action
ID NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
El Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info ft 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: 6/1/2020
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
❑r Yes ❑ No
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of(HAP)Emissions? El Yes El No
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G? (] Yes El No
hillSAlkiCOLORADO
Form APCD--211 Gam Venting APEN - Revision 12:'2019 2 I
Page 6 of 37
Permit Number: AIRS ID Number: 1 23 /A043/
ii:aa•ra bLank unless ss APCD has au each?agned per _N`acid AiR.S C)1
Section 4- Process Equipment Information
Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/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? El Yes ❑ No
VentGas2 442 BTU/SCF
Gas Venting Heating Value: ,
Process Parameters5: Requested: 4.40 MMSCF/year Actual: -_ MMSCF/year
-OR-
Liquid Throughput
Process Parameters5: Requested: bbl/year Actual: bbl/year
Molecular Weight: 43.7194
VOC (Weight%) 77.2116
Benzene(Weight%) 0.3069
Vented Gas Toluene (Weight%) 0.2825
Properties: Ethylbenzene (Weight%) 0.0102
Xylene (Weight%) 0.0581
n-Hexane(Weight%) 2.6582
2,2,4-Trimethylpentane (Weight%) 0.0013
Additional Required Documentation:
p Attach a representative gas analysis(including BTEX&n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX a 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.
iso.00L0RAD0
Form APCfl-21'1 Gas Venting APEN - Revision 12%2019 3 I „ .an,:,, .
Page 7 of 37
Permit Number: AIRS ID Number: 1 23 /A043/
((edvt Diank,.I,l. - APv.D has ai`edgy dssigned i per inft ?ux il;l AMR` �1
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1 71225/-104.865401
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. (Feet) ( F) (ACFM) (ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward ❑Upward with obstructing raincap
❑ 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
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
O VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed:
•
Pollutants Controlled: VOCs, HAPs
Rating: NA MMBtu/hr
Type: Enclosed Combustor Make/Model: TBD
❑ Combustion Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Unknown Waste Gas Heat Content: 2,442 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 0.025 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency: %
COLORADO
Form APCD-211 Gas VerstinG APBs' - Revision 12/2n19 4 I lee "„
Page 8 of 37
Permit Number: AIRS ID Number: 123 /A043/
,a;,_biaiik un'c,s APCD ire< r r,Sisn-s a psrn 1 id AIRS 21
Section 7- Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑� Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency
p (%of total emissions captured (%reduction of captured
by control equipment) emissions)
PM
5O1,
NO.
CO
VOC Enclosed Combustor(ECD) 100% 95%
I-IAPs Enclosed Combustor(EGO) 100% 95%
Other:
From what year is the following reported actual annual emissions data? N/A
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,, 0068 IbIMMBtu AP-42 -- -- -- 0.37
CO 0.31 Ib/MMBtu AP-42 — -- -- 1.70
VOC 89,067 lb/MMscf Site Specific - - 195.95 9.80
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.) (Ibs/year) (lbs/year)
Benzene 71432 354 Ib/MMsd Site Specific 1.558 77.89
Toluene 108883 326 Ib/MMsd Site Specific 1,434 71.70
-
Ethylbenzene 100414 11.77 lb/MMscf Site Specific 51.77 2.59
Xylene 1330207 67.02 lb/MMsef Site Specific 295 14.74
n-Hexane 110543 3.066 Ib/MMscf Site Specific 13,492 675
2,2,4-Trimethylpentane 540841 150 Ib/MMsd Site Specific 6.60 0.33
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
COLORADO
Form APCD-211 Gas Venting APEN - Revision 12/2019 5 I ieORAD
Page 9 of 37
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Permit Number: AIRS ID Number: 123 /A043/
[Leave htAlq. APCD has 3lr a.1i ;r.y;Igned a ppmht , and ARS;
Section 9 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
,�' ' ' .` ' % 5/27/2020
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:
0 Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 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
COLORADO
Form APCD 211 Gas Venting APEN Revision 1212019 6 ( ', :
Page 10 of 37
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