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Home My WebLink About20203705.tiff 7, COLORADO C Department of Public Health&Environment RECEIVED NOV 3 0 2020 Weld County Clerk to the Board WELD COUNTY COMMISSIONERS 1150 o St 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 - Grant Hurt 14H-G268 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 tw 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Fes' , IN It Jared Polls, Governor I Jilt Hunsaker Ryan,MPH, Executive Director , ,. Pu b I;c Re v; W GC:P1-(1?), HLCDS),PWCsn/ER/cH/cif), 2020-3705 l2./2I/ .o 12/11/20 -t*,,141-- Air Pollution Control Division o :.Y Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: Crestone Peak Resources Operating, LLC - Grant Hurt 14H-G268 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: Grant Hurt 14H-G268 Battery Oil and gas exploration and production facility SWNE Sec 14 T2N R68W Weld County The proposed project or activity is as follows: Source is requesting to modify the existing well production facility by decreasing throughput and emissions from the condensate loadout (point 001), converting coverage for the existing condensate storage tanks from GP01 to individual permit (Point 002), and adding a new point (006) for flaring of low pressure separator gas at the outlet of the buffer house when the VRUs are offline. 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 16WE0033, 20WE0489, 20WE0490 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: Carissa Money Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO Department of Public 1 I > _"" Health f3 Environment Denver, Colorado 80246-1530 COLORADO Department of Public 2 I co.xe Health&Environment 1.r.7 COLORADO 4. � Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 1 6WE0033 Issuance: 2 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Grant Hurt 14H-G268 Battery Plant AIRS ID: 123/9E3E Physical Location: SWNE quadrant of Section 14, Township 2N, Range 68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description LOAD-1 001 Truck loadout of condensate Enclosed Combustor(s) 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. 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,t VOC CO Type LOAD-1 001 --- --- 0.3 --- Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Page 1 of 8 x�C , ,:• COLORADO lor Air Pollution Control Division �i61-7 Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. 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 ID AIRS Point Control Device Pollutants Controlled LOAD-1 001 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit LOAD-1 001 Condensate Oil Loaded 52,925 barrels The owner or operator must calculate 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 6. 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) 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) Page 2 of 8 �_ COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12-month basis must control emissions from loadout upon exceeding the loadout threshold. 9. Storage tanks must operate without venting at all times during loadout. Compliance must be achieved in accordance with the schedule in Regulation Number 7, Part D, Section II.C.5.a. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 10. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back-pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. Compliance must be achieved in accordance with the schedule in Regulation Number 7, Part D, Section II.C.5.a. 11. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. Page 3 of 8 C :' COLORADO Air Pollution Control Division GOPFI Department of Pubt:c Health&Enveronment Dedicated to protecting and improving the health and environment of the people of Colorado • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. Compliance must be achieved in accordance with the schedule in Regulation Number 7, Part D, Section II.C.5.a. 12. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. • Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. • Records of the infeasibility of observation of loadout. • Records of the frequency of loadout. • Records of the annual training program, including the date and names of persons trained. Compliance must be achieved in accordance with the schedule in Regulation Number 7, Part D, Section II.C.5.a. 13. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 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 Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. Page 4 of 8 •rrY- COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 17. All previous versions of this permit are cancelled upon issuance of this permit. 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5) tons per year,whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. 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. 20. 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 5 of 8 ,,ix. COLORADO Air Pollution Control Division Department of Public Health&Environment 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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: Carissa Money Permit Engineer Permit History Issuance Date Description Issued to Crestone Peak Resources Operating, Issuance 1 May 25, 2017 LLC. Transfer of ownership from Encana Oil Et Gas (USA) Inc. before completion of issuance. Convert from site-specific emission factors to Issuance 2 This Issuance state default. Reduce throughput from 899,620 bbl/yr and reduce emissions from 7.3 tpy VOC. Page 6 of 8 C11P C O L O R A D O Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See. 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 PointPollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 22 1 001 n-Hexane 110543 191 10 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: Uncontrolled Controlled Emission Emission Pollutant CAS # Factors Factors Source lb/bbl lb/bbl VOC 0.2360 0.0118 CDPHE Benzene 71432 0.0004 0.00002 CDPHE n-Hexane 110543 0.0036 0.0002 CDPHE Controlled emission factors are based on a flare control efficiency of 95%. Page 7 of 8 CM.• COLORADO ii_� Air Pollution Control Division 7 Department of Public Health ET Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 website listed below: http://www.ecfr,g,ov/ 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 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: CarissaMoney Package 6: 479406 Received Date: 4/24/2020 Review Start Date: 10/6/2020 Section 01-Facility Information Company Name: Cresthine Peak Resources Operating,LLC Quadrant Section Township Range County AIRS ID: 123 SWNE 14 `2N 68 Plant AIRS ID: 943E Facility Name: Grant-lila IP H0266 Batten/ Physical Address/Location: _ _, County: Weld County Type of Facility: Exploration.gs Production Wail Pad What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAFIS non-attainment area? - Yes If yes,for what pollutant? Ozone(NOx&VOCi Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRS Point# Permit# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APED has already # Required? Remarks has already assigned) assigned) Permit 001 Liquid Loading LOAD-1 Yes 161r/6000SS 2 No Modification in _-- Converting:.. from'GP01 to Permit initial individual 002 SC- age Tank TANKS Yes 2 WE0455 _ Yes issuance_- permit Permit initial 006 Separator Venting_ cBuffer. Yes- 2CWE0193 _ Yes Issuance Section 03-Description of Project 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 loadout,condensate storage vessel and produced water storage vessel sources in addition to adding a new source for flaring of natural gas from the low pressure separators. - For the loadout,the source is,requesting to convertfrom site-specific emission factors to state default emissions factors and reduce throughput.A final approval was issued for this permit on 11/27/2017.Since the source is using state default emission factors and reducing throughput,self-certification is not required.The permit will be issued as final approval. For the condensate storage tanks,the source is requesting to convert the existing OPUS coverage for the source to an individua I permit.Additionally,the operator is updating the site specific emission factors,throughput and emissions to.reflect current conditions.This permit will require self-certification. For the produced water tanks,the source is updating the AP EN based on removing a control device but retaining OPUS coverage and retaining the use of the state default emission factors. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit - Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Na - If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? - No Is this stationary source a synthetic minor? - Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) _ J. ❑ _ ❑ ❑ Title V Operating Permits(OP) © ILf Non-Attainment New Source Review(NANSR) J Is this stationary source a major source? No If yes,indicate programs and which pollutants: S02 NOx CO VOC PM2.5 PM1D TSP HAPs Prevention of Significant Deterioration(PSD) — ❑ ❑ ❑ Title V Operating Permits(OP) (L_J7 Non-Attainment New Source Review(NANSR) ydrecarbcr Loadout Ernission>inventory Section 01-Administrative Information Facility AIRS ID: E '� 9640 001 County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit HY0POCarbon leadOtittotaitittrgcks Description: Emission Control Device -i Enc W dontGtest'On Description: Is this loadout controlled? Requested Overall VOC&HAP Control Efficiency%: 95 Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Hydrocarbon Loadout Actual Volume Loaded= Barrels(hbl)per year I Requested Permit Limit Throughput= 52,925 Barrels(bbl)per year Requested Monthly Throughput= 4335 Barrels(bbl)per month 1 Potential to Emit(PTE)Volume Loaded= 63,510 Barrels(bbl)per year Secondary Emissions-Combustion Devices) Heat content of waste gas= 2564.9 Btu/scf Actual Volume of waste gas emitted per year= V scf/year The source calculated combustion emissions based on site-specific values for MW,temperature and heat content.These cells have been adjusted Requested Volume of waste gas emitted per year= ?'2n2e scf/year Actual heat content of waste gas routed to combustion device= , MMBTU per year 446.2041881 Requested heat content of waste gas routed to combustion device= -MMBTU per year Potential to Emit(PIE)heat content of waste gas routed to combustion device= .3 MMBTU per year Control Device Pilot Fuel Use Rate: scfh ,.4 MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf 6•?MMBTU/yr Section 04-Emissions Factors&Methodoloyles Does the company use the state default emissions factors to estimate emissions? ��'• Does the hydrocarbon Squid loading operation utilize submerged fill? .,z. .. +:;:e=as.:t o .t0r5...a,30•,srU•n „t•n*-sse.Oisva,•, Emission Factors Hydrocarbon Loudest Uncontrolled Controlled Emission Factor Source Pollutant (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC 4 0100 0110 Benzene ..__o- Toluene 0 0003 Ethylbenzene O:JCO1 40000 Xylene Sac: 0.00co n-Hexane 000000,4002 224 TMP OW Control Device Pollutant Uncontrolled Uncontrolled Emission Factor Source (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 PMZ.S • 06075 4.41:05 p.-h. PMSO 25) 5O0 'WAX` 3.48E Ot; G T, -1,5 NOx 41065 DOi,fi4 ant t•;;.S CO Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) Emission Factor Source (Pilot Gas (Waste Heat Combusted) Throughput) PM30 d.0O03 PM2.5 0.0000 3.46 Sox 3000 NOx VOC CO 4.0000 2 of 10 C:\Users\cdmoney\Documents\Package 429466\16WE0033.CP2 '-,•,01(3:.):3011)::, (.i)cty ... .,.-; - Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 0,9u 0-C. 0 JL= ., PM2.5 :+.:I0 O :. Sox 0.511 0 0.) 0.0.0 .J.•': ,1.:,. . NOx 0.31 Ill .IU - '-' - VOC ?a, 010 ., .31 Si CO .,..I .Of. .t.08 .,..5 .i._ a Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year) (ibs/year) Benzene :s5 , 0 ._ - Toluene . Ethylhenzene _ . Xylene 3 C . n-Hexane ... 224TMP „ , 0 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7 Part D Section ll.C,5. I,1 IoU x.,cboc' :.•,:ao..,r;.,,;t„ ....,. .. „ (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements .i 8 W Does The company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes Typically when urine state default emission factors,the source can also use state default factors for estimating combustion emissions.The source chase to adjust the combustion missions based on site-specific gas molecular weight,heat content and temperature.This change resulted in higher emissions than if usingthe State default.However,emissions are still below APEN thresholds.Pilot light emissions are accounted for at the storage tanks(AIRS ID 002)since a bank of combustors is use!f to control multiple"sources. - tanks .e ' • • Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Point 9 Process B SCC Code Pollutant Factor Control% Units 001 01 PM10 t.8 lb/1,000 gallons transferred PM2.5 .... lb/1,000 gallons transferred Sox .. lb/1,000 gallons transferred NOx lb/1,000 gallons transferred VOC 5 lb/1,000 gallons transferred CO 0 lb/1,000 gallons transferred Benzene .- as 16/1,000 gallons transferred Toluene lb/1,000 gallons transferred Ethylbenzene .. . v lb/1,000 gallons transferred Xylene .- lb/1,000 gallons transferred n-Hexane ., lb/1,000 gallons transferred 224 TMP , us lb/1,000 gallons transferred 3 of 12 C:\Users\cdmoney\Documents\Package 429466\16WE0033.CP2 Hydrocarbon Loadout Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions and throughput. Colorado Re ulation 3 Parts A and B-APEN and Permit Requirements Source is in the ilea-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section II.3.3)? 'You have indicated that source is in the Neon-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.l.a)? R4,§. Go to next question. 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section II.D.1.1(? Yihi Go to the next question 3. Is the loadout operation loading less than 10,000 gallons(238 BBLs)of crude oil per day on an annual average basis? Go to next question 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? Ho Go to next question 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? Nc, Go to next question 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part 8,Section II.D.2)? The loadout requires a permit ISeance requires a permit Colorado Regulation 7 Part D Section II.C.5. 1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility,natural gas compressor station or natural gas processing plant? ?' Go to next question. 2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels? Source is subject to Regulation 7 F 'The hydrocarbon liquids loadout so.. us it DSc,• Section II.C.5.a.(i)-Compliance Schedule Section II.C.5.a.(li)-Operation without Venting Section II.C.5.a.(iii)-Loadout Equipment Operation and Maintenance Section II.C.S.a.(iv)-Loadout observations and Operator Training Section II.C.S.a.(v)-Records Section II.C.5.a,(vl)-Requirements for Air Pollution Control Equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must'and'required"areintended 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. Storage 1znlc 5t Emks)ons inve s ory Section 01-Administrative Information Facility AIRS ID: 123 SEW 002 County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Detailed Emissions Unit 4ighE At3`A)nl Xeidie Bconctensatqgtareieveesefs connected vr31iquyd on tiifold Description: 52965.15 Emission Control Device ttctdsecliosnbtrstosv .: Description: Requested Overall VOC&HAP Control Efficiency%: &5,0. Limited Process Parameter "R e"S, rCt .: Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tan(s(s) Actual Throughput= . Barrels(bbl)per year (Requested Permit Limit Throughput= '52,925.0 Barrels(bbl)per year Requested Monthly Throughput= 44950 Barrels(bbl(per month Potential to Emit(PTE)Condensate Throughput= 63,510.0 Barrels(bbl)per year • Secondary Emissions-Combustion Device(s) Heat content of waste gas= 2544.7 Btu/scf • Volume of waste gas emitted per BBL of liquids • • produced= 136.7 scf/bbl Actual heat content of waste gas routed to combustion device= C MMBTU per year Requested heat content of waste gas routed to combustion device= 13 16-'..5 MMBTU per year Potential to Emit(PTE(heat content of waste gas routed to combustion device= _<.183 MMBTU per year Control Device Pilot Fuel Use Rate: .;'200 scfh I S MMscf/yr Pilot Fuel Gas Heating Value: . 1000 Btu/scf :261.0 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? J.4 Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 13 0500 0.6530 Benzene 0.02328 0 0012 Toluene 0.01770 0.0009 Ethylbenzene 0.0'4=050 0.0090 X lane 0.00331 0.0002 n-Hexane 0.26511 0.01'4 224 TMP 0.0002 . 0,00CD ... TaG , a -9, Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) " Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 021075 0 0026 PM2.5 0.0075 0.0026 e' SOx 0.0000 ! fe1 pA2₹'..,�fl' .9 NOx 0.0680 0.0236 i.42 ha to x 5 lorrootriati7a,,(ng[jy1 L CO ,.:0.3100 0.1075 AP-42 ,13.3 19209,10 Pilot Light Emissions Uncontrolled Uncontrolled - Pollutant (lb/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 0.0075 74 ': F �•s.0 PM2.5 0.2275 7.^,. Ts^ SOx 0 090, 0,511: i 22. 0i0 991 919.. NOx 60.00 C VOC G.0254 5.3922 OP-92 2.92 .,9 CO 0,3100 310 0960 .AP 42 C.,z 5 of 12 C:\Users\cdmoney\Documents\Package 429466\16WE0033.CP2 Storage Tank(s)Emissions inventory Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants I Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM30 __ 0 0 0.0 0.1 9.- 12.8 PM2.5 0_ 0.0 0.0 0.1 31 12.8 SOx 0.3 0.0 0.0 0.0 0.0 9.1 NOx 9 0.1 0.1. 0.09 0.7 116,x VOC 4007 0.0 0-0 340.0 17.3 29300.0 CO 3.7 0.3 0.3 3.12 3,1 530.7 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (lbs/year) (Ibs/year) (Ibs/year) (lbs/year) Benzene 5.230 0.0 0.0 __.. 53 Toluene _,__1 0.0 0.0 _3 -_. Ethylbenzene - _ 0.0 0.0 31 .. Xylene -_. 0.0 0 201 _7 n-Hexane 0.0 0..^3. ,r05, .. 224TMP 0,0 13 _ Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B reacs iron a norm: Regulation 7,Part D,5ection I.C,0,E,F Regulation 7,Part D,Section I.G,C Regulation 7,Part D,Section II.B,C1,C.3 .. _. Regulation 7,Part D,Section II.C1 .. - Regulation 7,Part D,Section II.C.4.a.(i) Regulation 7,Part D,Section II.C.4.a.(ii) Regulation 6,Part A,NSPS Subpart Kb .. , Regulation 6,Part A,NIPS Subpart 0000 .51, S,Ibiectro IJSP"s 0000 NSPS Subpart 0000a JOa- Regulation 8,Part E,MACE Subpart HH (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors t r §". estimate emissions? xd If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than equal to 20 tons VOC per year OR are the uncontrolled actual or requested emissions fora condensate storage tank estimated to be greater than or equal to 80 toy? 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? p3 t•w If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample should be considered representative which generally means site-specific and collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to use an older site-specific sample.. - If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? `' If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes The source used Promax:along with site-specific pressurized liquids sample from the inlet of the high pressure separator and a sales gas sample at the inlet to the high pressure separator(both collected 2/5/2020)to estimate emissions from the downstream equipment including the low pressure separator venting and condensate storage tanks.I confirmed the samples matched the stream compositions,temperature and pressure in Promax.The source used Nome to estimate flashing missions as well as working and breathing emissions by using the Tankgoss stencil..The Tank Loss stencil was originally based on the material category"heavy crude."I asked the source to revise the modeIto:be based on light organ cs."The source provided revised emission estimates on 10/12/2020.' Site-specific emissions fora condensate storage tank with flash must be based on a sample collected immediately prior to the inlet of the tank.Since the application is based on a pressurized liquids sample collected at the outlet of the high pressure separator and not immedicatew prior to the inlet of the conks,the:permit will require the source to collect an initial sample immediately before the tanks to confirm emissions In comments on the draft permit,Sabrina Pryor with Crestone clarified that emissions from the loadout,condensate tanks,and buffer house are vented to a bank of combustors and requested to account for total pilot light emissions at the storage#auks.Its appropriate to account for total pilot light emissions at the highest emitting unit and not split the pilot light emissions among the emission units.Thus,pilot light emissions were increased from 25 scf/hr to 291 scf/hr to represent total pilot light emissions from a maximum of eight cdmbustors(25 scf/hrx 8). Section 09-SCC Coding and Emisslees Factors$For Inventory Use Only) Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control%Units • 01 ", PM10 0,07 0 lb/1,000 gallons Condensate throughput PM2.5 307 0 lb/1,000 gallons Condensate throughput 5Ox .,c.. 0 lb/1,000 gallons Condensate throughput NOx 0,02 0 lb/1,000 gallons Condensate throughput VOC 31396 95 lb/1,000 gallons Condensate throughput CO 2-03 0 lb/1,900 gallons Condensate throughput Benzene 0.17 95 lb/1,000 gallons Condensate throughput Toluene 1-4_ 95 lb/1,000.gallons Condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons Condensate throughput Xylene 0.09 95 lb/1,000 gallons Condensate throughput n-Hexane 4.05 95 lb/1,000 gallons Condensate throughput 224 TMP 7.01 95 lb/1,000 gallons Condensate throughput Ref 12 C:\Users\cdmoney\Documents\Package 429466\16WE0033.CP2 Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. • Colorado Regulation 3 Parts A and B-APEN and Permit Requirements • 'Source is in the Npa-A₹tairusrass:Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Part A,Section II.D.La)? 2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 55 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section lI.D.3)? You have indicated that source is In the Non-Attainment Area NON-ATTAINMENT I. 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)? Source Requires an APEN.Go to , 2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1,12 and1.14 and Section 2 for additional guidance on grandfather applicability)? Go to next question 3. Are total facility uncontrolled VOC emissions greater than 2TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D.2)? ,f6ii* gs Source Requires a permit 'Source requires a permit Colorado Regulation 7,Part D,Section I.C-F&G 1. Is this storage tank located In the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section I.A.1)? Yes Continue-You have indicated th 2. Is this storage tank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 7,Part D,Section I.A.1)? Yes Continue-You have indicated th 3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part D,Section I.0)? No Storage Tank is not subject to Re 4. Does this storage tank contain condensate? Yes 5. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,part D,Section 1.0.2)? Yes 6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section I.D.3.a(ii))? IStnirage tank is subject to Raitsilasioo 6 Part 0,Sect-son LC-F Part 0,Section J.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part D,Section I.C.2—Emission Estimation Procedures Part D,Section I.D—Emissions Control Requirements Part D,Section I.E—Monitoring Part D,Section I.F—Recordkeeping and Reporting Storage rank is not subject to Regulation 7,Section i-(:, Part D,Section I.G.2-Emissions Control Requirements Part D,Section I.C.1.a and b—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Colorado Regulation 7,Part D,Section II 1. Is this storage tank located at a transmission/storage facility? No Continue-You have Indicated th 2. Is this storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor station'or natural gas processing plant°(Regulation 7,Part D,Section II.C)? Yes Go to the next question-You ha 3. Does this storage tank have a fixed roof(Regulation 7,Part D,Section ll.A.20)? yes-> Go to the nett question 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section ll.C.1.c)? Yes `=Source is subject to parts of Regi (Storage tank is subject tes itegulatisso'7,Part 0,Section it,ii,t , Part 0,Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part D;Section II.C.1-Emissions Control and Monitoring Provisions Part 0,Section II.C.3-Recordkeeping Requirements 5. Does the storage tank contain only"stabilized"liquids(Regulation 7,Part D,Section II.C.2.b)? No ISource is subject to all provision: I Staraye.tamia is subject to Regulation 7,Part Li,Section 11 5.2 .. Part D,Section II.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified on or after May 1,2020,such 6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section II.C.4.a.(i)? Nu r'Storage Tank is not subject to Re (Storage 1 ank is nut.subject to Regulation 7,Pant 0,Sections II.C.4.a(il Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or afterJanuary 1,2021 or located at a facility that was modified on or afterJanuary 1, 7. 2021,such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part 0,Section II.C.4.a.(ii)? Ncr IStorage Trish is nut sua(ect to Regulation 7,Part is,Sections 11.5 4.0(115 kit-f 40 CFR,Part 60,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels 1, Is the individual storage vessel capacity greater than or equal to 75 cubic meters(m5)["472 BBLs](40 CFR 60.110b(a))? Yin- ,s Go to the next question 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? - Yes Storage Tank is not subject MPS a.Does the vessel has a design capacity less than or equal to 1,589.874 mu[^10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 60.1116? 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)afterJuly 23,1984(40 CFR 60.110b(a))? 4. Does the tank meet the definition of"storage vessel,"3 in 60.1116? G. Does the storage vessel store a"volatile organic liquid(VOL)"s as defined in 60,111k? 6. Does the storage vessel meet any one of the following additional exemptions: a.Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa[^29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))?;or b.The design capacity is greater than or equal to 151 m'[`950 BBL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa(60.110b(b))?;or c.The design capacity is greater than or equal to 75 Ma[-472 BBL]but less than 151 ma["950 BBL]and stores a liquid with a maximum true vapor pressure'less than 15.0 kPa(60.110b(b))? 7. Does the storage tank meet either one of the following exemptions from control requirements: a.The design capacity Is greater than or equal to 151 ma[^950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or b.The design capacity is greater than or equal to 75 Ms]'"472 BBL]but less than 151 ma[^950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? Storage Task as not subject to:J F1 Ilk 40 CFR,Part 60,Subpart 0000/0000a,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution 1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the Industry? T. Continue-You have indicated th 2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,2015? . . Go to the question 4. 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015? 'L: Storage Tank is not subject NIPS 4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? Storage Tank is not subject NIPS 5. Does this storage vessel meet the definition of"storage vessel"'per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart H H? Storage'Tank is not su]q]imct to NSW"S 0000 [Note:If a storage vessel is previously determined to be subject to NIPS 0000/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NIPS 0000/OOOOa per 60.5365(e)(2)/60.5365a(e)(2)even if potential VOC emissions drop below 6 tons per year] 40 CFR,Part 63,Subpart MACT HH,Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: 1 Continue-You have indicated th a.A facility that processes,upgrades or stores hydrocarbon liquids')63.760)a))2));OR b.A facility that processes,upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'(63.760(a)(3))? 2. Is the tank located at a facility that is major'for HAPs? Na >.Storage Tank is not subject MAC 3. Does the tank meet the definition of"storage vessel""in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63,761? 5. Is the tank subject to control requirements under40 CFR Part 60,Subpart Kb or Subpart OOOO? Storage Tank is not subject to MALT HP3 Subpart A,General provisions per§63.764(a)Table 2 §63.766-Emissions Control Standards §63.773-Monitoring §63.774-Recordkeeping §63.775-Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area.If the tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation, or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulations, and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. Section 01-Administrative Information Facility AIRs ID: 123 9E3E 006 County Plant Point Section 02-Equipment Description Details Flaring of natural gas vented from the low pressure side of three(3)high/low pressure separators and routed through the buffer house. Detailed Emissions Unit Description: • Enclosed 0otnbustor(s)during vapor recovery unit(VIW)downtime .. Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency Y: 95 Limited Process Parameter ZLl'§Aktglfitg 44CM.M_LM.Mi Gas meter ,{ "Pg, £_ i ij°` F=' Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= MMscf per year I Requested Permit Limit Throughput= 0.6 MMscf per yeer Requested Monthly Throughput= of MMscf per month Potential to Emit(PTE)Throughput= r.s MMscf per year Secondary Emissions-Cnmbustios'Device(s)for Air Pollution Control Separator Gas Heating Value: 1972.3 Btu/scf 1698.9 gross ideal heating value for Promax Buffer Gas stream Volume of waste gas emitted per BBL of ligniNalteaflq liquids throughput: :scf/bbl 9 Control Device Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf `1+ HM0. Section 04-Emissions Factors&Methodologies Description The Snare uue.O Prating o1o0gwithlAaite+Speeifiiu pressurizedliquidssamplefromthe€nletofthehighpressureseparatorandasa₹es gas sample at the inlet to the high pressure separator(hotly collected 2/5/2020)to eAtirairdoriff4tpirermille dovmstreArrt equipment Me low pressure separator venting and storage tanks.I confirmed The samples matched the stream cotoposilony temperature and pressure in Pro max.The LP ₹aftaratooguSl maid t iSugh an exchanger and alien to the buffer house.While the source included the yeoman model with the application,the stream composition used to establish permit limits is based off a site-specific gayu r01.pogoll0ututfdi lt2.t attfui outlet of the buffer house The site-specific sample has a higher VOCwt%of 60%vs 46.9wt%.VOC predicted by Promax. MW f - 34,616/Ib-mol Displacement Equation Ex=Q`MW Xx/C Weight% Helium - . - .• - . • - " - • _. CO2 2,0126 3.6 52 0.5847 0.1 methane 15.7810 24.1 • ethane 21.5407 25.3 propane 27%062 23.1 isobutane 5.4747 4.2 n-butane 13.7958 10.5 isopentane 3.8786 2.8 n-pentane • 4.4097 3.1 cyclopeetane 0.2330 0.2 n-Hexane 1,1331 0.7 cyclohexane 0:2084 0.2 Other hexanes 1.0716 1.1 hepta nes 0.5.360 5.4 methylcyclohexane 5.2159 0.2 224 TMP 0 000 0.0 Benzene 01302 0.1 Toluene 0:.0941 0.1 Ethylhenzene 0.0039 0.0 Xylenes .-- e027:1 0.0 CB+Heavies 0.4023 0.1 Total VOC Wt% • • 9 of 12 C:\Users\cdmoney\Documents\Package 429466\16WE0033.CP2 Separator\tenting Emissions inventory Emission Factors Separator Venting Uncontrolled Controlled Emission Factor Source Pollutant (Ih/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 54700 i 'E.4p; Benzene 113.84 - Toluene 35.962 .... Ethylbenzene 3.5627 Xylene 2'4.756 n-Hexane 103 7.0 ,.. 224TMP 0.3618 2,"._3 Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 40070 :4.6453 F 4Z able"`2{r PM2.5 .,07E 14.6950 4E�)ZIs�2I SOx {722006 160�J -42T`.t o 1 dt.3'..ISOu'q, NOx 00600 154.12 13c,Indus3L 0(81 s( CO 0,3100 S11.2.1 23 -.22'? "' „40 ml nip ,r,) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MM Btu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 - 00005 PM2.5 0.0005 SOx 0 0000 NOx 3.000' VOC 2.0000 CO 0.0004 Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) Ohs/month) PM10 0.0 .2.0 0,0 0 PM2.5 C.P. 0.0 0.0 C.;t 0 0 a SOx 4.1 0.0 0.0 _.7 0.0 NOx 3.4 0.0 7,0 9:1, 0.4 75 VOC isi,:J 0.0 3.0 7.33.0 0.0 ..128 CO 2.3 0.0 3.0 2.°'_- 2 7 '3 41 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (165/year) Obs/year) (Ibs/year) Ohs/year) (lbs/year) Benzene 732 0 0 )32 39 Toluene '5o_ 0 8 0E5 Za Ethylbenzene 23 0 0 23 1 Xylene _63 0 0 103 0 n-Hexane 5685 0 0 0oal 334 224TMP 2 0 .. 2 v Section 06-Regulator,,SummaryAmalysis Regulation 3,Parts A,B Source recuires a permit Regulation 7,Part D,Section II.B,F Source!s seb ea'_o Segu"ation 7,Tart 0,Sechec 9.8 2.P Regulation 7,Part D,Section 11.82.e ''he contrci device'e,this separator i,no_subject to Re_ulaHon 7,Pe.rss D.Sect:00 I!.-i.2 e (See regulatory applicability wonksheet for detailed analysis) 10 of 12 C:\Users\cd money\Documents\Package 429466\16WE0033.CP2 • o \ . .. _ Section 07-Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID,and should have been collected within one year of the application received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to use an older site-specific sample. If no,the permit will contain an"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility-wide permitted emissions of VOC greater than or equal to 40 tons per year in the ozone nonattainment area OR are emissions greater than or equal to 90 tons per year in the ozone attainment area? o. If yes,the permit will contain: -An"Initial Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A"Periodic Testing Requirement"to collect a site-specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? • If no,the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational(not to exceed 100 days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 y„u have indicated above e€ aro,ess,v,r'y'aete: ,.-a:gat se.t-rd failo.viog n:-e-t:.a+_, e ail i Section 08-Technical Analysis Notes Typically,a new point requesting synthetic minor limits would require monthly limits forthe first 12 months of operation,Since this emissions unit is venting as a back-up only during VRU downtime,the downtime(and thus venting)will not happen.consistently throughout the year.Thus,for this venting scenario,it is appropriate to only require a 12-month rolling limit, Pilot light emissions are accounted for at the storage tanks(AIRS ID 002)since a bank of combustors is used to control multiple sources. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Units 006 01 ii .. -' PM10 q. vii•: PM2.5 ... SOx ,1 ••-. NOx ' VOC CO Benzene .I. Toluene • - .. Ethylbenzene • Xylene • ., n-Hexane 224 TMP • -• .. 11 of 12 C:\Users\cdmoney\Documents\Package 429466\16WE0033.CP2 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regelatinn 3 Parts A and B-APEN and Permit Requirements In the Non-Attainment Area ATTAINMENT I. Are uncontrolled actual emissions from any CYRAPIa pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D,1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section II.D.3)? 'You have indicated that source is in the Non Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section II.D.1.a)? Yes,._ ;,Source Re, 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section II.D.2)? Yes -'Source Re, 'Source requires a pernmit. Colorado Regulation 7,Part D,Section II 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? Yes ISource is s 'Source is subject to Regulation 7,Part D,Section 11.0.2,F Section 11.B.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative 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? ') ".'` The contrc IThe control device to this separator is net sutrlec:t to Regulation 7,Part Li,Section HALL, Section 11.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 not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulations, and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name Crestone Peak Resources Operating Site transferred from:Encana Oil&Gas(USA)Inc. County AIRS ID 123 - History File Edit Date 10/7/2020 Plant AIRS ID 9E3E Ozone Status Non-Attainment Facility Name Grant Hurt 14H-G268 EMISSIONS-'Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 442.4 0.0 0.0 27.0 0.0 0.0 0.0 0.0 0.0 56.3 0.0 , 0.0 1.3 Based on July 2015 tab for Points 001-003 Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 442.4 0.0 0.0 27.0 0.0 0.0 0.0 0.0 0.0 56.3 0.0 0.0 1.3 001 16WE0033 Truck Loadout 0.0 6.2 0.1 0.1 0.0 0.3 0.1 0.0 Converting to state default EF.Reduce throughput and emissions from 7.3 tpy controlled VOC. 002 20WE0489 8 500-BBL condensate tanks 0.1 0.1 0.7 345.6 3.1 6.7 0.1 0.1 . 0.7 17.3 3.1 0.3 Converting from GP01 to individual permit.Updating emission factors and throughput 003 GP05 4 250 BBL produced water tanks 1.9 0.2 10.0 0.2 Update to account for removal of control device. Retain state default EF 004 17WE09J7..k'P,CN VFRU compressor-Zenith (1.0 0.0 Cancellation received 2/12/2019 005 19WE0752.XP VRU compressor-Compressco 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 Based on APEN received July 2019 GJ230 46 hp 006 20WE0490 LP separator venting 0.4 180.0 2.0 4.1 0.4 9.0 2.0. 0.2 New point 0,0 _ 0,0 Hi Low Separators 0.2 0.0 0.2 0.0 0.2 0.0 0.2 0.0 Based on Form 102 Bulk Heater Treater 0.1 0.1 1.5 0.1 1.3 0.0 0.1 0.1 1.5 0.1 1.3 0.0 Based on Form 102 Fugitives 0.6 0.0 0:6 0.0 Based on Form 102 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.2 0,2 0.0 0.0 10.1 534.2 0.6 15.0 11.3 0.2 0.2 0.0 0.0 3.7 37.1 0.6 8.5 0.9 VOC: Syn Minor(NANSR and OP) NOx:Minor(NANSR and OP) CO: Minor(PSD and OP) HAPS: Minor Permitted Facility Total 0.1 0.1 0.0 0.0 1.1 533.7 0.0 52 11.2 0.1 0.1 0.0 0.0 1.1 356 0.0 5.2 0.8 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions O./ 0.1 0.0 0.0 1.1 -19.7 0.0 5.2 Public comment required for new syn minor limit Total VOC Facility Emissions(point and fugitive) 37.7 Facility is eligible for GP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) -19.7 Project emissions less than 25/50 tpy Note 1 Note 2 • • • Page I of 2 Printed 11/12/2020 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 9E3E Facility Name Grant Hurt 14H-G268 Emissions -uncontrolled(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0033 Truck Loadout 22 191 0.1 002 20WE0489 8 500-BBL condensate tanks 1269 937 32 201 11011 13 6.7 003 GP05 4 250 BBL produced water tanks 102 321 0.2 004 17WE0997.XP.CN VRU compressor-Zenith 0.0 005 19WE0752.XP VRU compressor-Compressco GJ230 2 89 0.0 006 20WE0490 LP separator venting 782 565 23 163 6685 2 4.1 0.0 Hi Low Separators 8 0.0 Bulk Heater Treater 55 0.0 Fugitives 50 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 1.1 0.8 0.0 0.2 9.2 0.0 _ 0.0__ 0.0 O.0 11.3 I *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text uncontrolled emissions<de minimus Emissions with controls(lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 16WE0033 Truck Loadout 1 - 10 0.0 002 20WE0489 8 500-BBL condensate tanks 63 47 2 10 551 1 0.3 003 GP05 4 250 BBL produced water tanks 102 321 0.2 004 17WE0997.XP.CN VRU compressor-Zenith 0.0 005 19WE0752.XP VRU compressor-Compressco GJ230 2 89 0.0 006 20WE0490 LP separator venting 39 28 1 8 334 0.1 0.2 0.0 Hi Low Separators 8 0.0 Bulk Heater Treater 55 0.0 Fugitives 50 0.0 0.0 0.0 TOTAL(tpy) 0.0 0.0 0.0 0.1 0.0 0.0 0.0 0.7 0.0 0.0 0.0 0.0 0.9 2 1239E3E 11/12/2020 . COLORADO tC .,,y.... Air Pollution Control Division 3i om/ Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0489 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Grant Hurt 14H-G268 Battery Plant AIRS ID: 123/9E3E Physical Location: SWNE quadrant of Section 14, Township 2N, Range 68W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Eight (8) 500 barrel fixed roof condensate Enclosed TANKS 002 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 �� M•;=�• COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type TANKS 002 --- 0.7 17.3 3.1 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 Control Device Pollutants Equipment ID Point Controlled TANKS 002 Enclosed Combustor(s) VOC and HAP Page 2 of 10 Cwo COLORADO 40CAir Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Process Process Parameter Annual Limit Equipment ID Point TANKS 002 01 Condensate throughput 52,925 barrels 02 Combustion of pilot light gas 1.8 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. 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 Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. Page 3 of 10 COLORADO Air Pollution Control Division cDPHE Department of Publac Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 0ftM 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 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. Page 4 of 10 ��-r,�.•�.. COLORADO ipM ate' �. Air Pollution Control Division �� Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Permit Number Number Emission Point GP01 123/9E3E/002 20WE0489 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 (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. 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 5 of 10 z COLORADO Air Pollution Control Division ea Department of Public Health Er"Environment 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: Carissa Money Permit Engineer Page 6 of 10 Cy * • COLORADO Air Pollution Control Division taf Department of Pubtfc Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC. Converting from GP01. Permit for eight (8) 500 bbl condensate storage vessels at an existing well production facility. Page 7 of 10 r'YYY< COLORADO Au Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,269 63 Toluene 108883 937 47 Ethylbenzene 100414 32 2 002 Xylenes 1330207 201 10 n-Hexane 110543 11,011 551 2,2,4- 540841 13 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. 5) The emission levels contained in this permit are based on the following emission factors: Point 002: Process 01: Condensate Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0236 0.0236 AP-42 Chapter 13.5 Page 8 of 10 CCOLORADO `'�iii►-� Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 0.1078 0.1078 AP-42 Chapter 13.5 V0C 13.0600 0.6530 ProMax 71432 Benzene 0.02398 0.0012 ProMax 108883 Toluene 0.01770 0.0009 ProMax 1330207 Xylene 0.00381 0.0002 ProMax 110543 n-Hexane 0.20804 0.0104 ProMax Note: The controlled emissions factors for this point are based on the enclosed combustor 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 and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the outlet of the high pressure side of the high/low pressure separator for the Grant Hurt 14H-G268 battery on 2/5/2020. The sample pressure and temperature are 213.9 psig and 55°F respectively. The AP-42 Chapter 13.5 CO and NOx emission factors in the table above were converted to units of lb/bbl using a gas-to-oil ratio (GOR) of 136.7 scf/bbl and a heat content of 2,545 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 N0x 68.0 68.0 AP-42 Chapter 13.5 CO 310.0 310.0 AP-42 Chapter 13.5 Note: The emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 emission factors 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 200 scf/hr. Monthly pilot light gas throughput shall be determined by multiplying this hourly pilot gas throughput by the enclosed combustor monthly hours of operation. There are up to eight enclosed combustors each equipped with a pilot light (rated at 25 scf/hr each) used to control emissions from the condensate storage vessels, hydrocarbon loadout and buffer house. Total actual emissions are obtained from the sum of emissions resulting from the storage vessels and combustion of waste gas from the storage vessels (process 01) and the combustion of pilot light gas (process 02). 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point Page 9 of 10 C4.. , ..y........!-� COLORADO Air Pollution Control Division ` Department of Public Wealth&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 ��.,r- COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0490 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Grant Hurt 14H-G268 Battery Plant AIRS ID: 123/9E3E Physical Location: SWNE quadrant of Section 14, Township 2N, Range 68W 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 three (3) high/low Buffer 006 pressure (HLP) separators and routed Enclosed 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 https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 9 Cv , COLORADO 4.44.40..CDPHE.... Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO,t VOC CO Type _ Buffer 006 --- 0.4 9.0 2.0 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission 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.) Equipment ID AIRS Control Device Pollutants Point Controlled Page 2 of 9 C1.4.1 COLORADO ,. Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Emissions from the low pressure side of three (3) high/low pressure (HLP) Buffer 006 separators are routed through the buffer VOC and HAP house to enclosed combustor(s) during vapor recovery unit (VRU) downtime. PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Natural gas vented from the low pressure Buffer 006 side of three (3) HLP separators and 6.6 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. 10. The owner or operator must continuously monitor and record the volumetric flow rate of gas vented from the low pressure side of three (3) 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 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)I.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be Page 3 of 9 C y. COLORADO w- Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 14. 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. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 16. 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 OO.M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING 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 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 4 of 9 . max- COLORADO Air Pollution Control Division NU, Department of Public Health&Envtronrnent Dedicated to protecting and improving the health and environment of the people of Colorado 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. GENERAL TERMS AND CONDITIONS 19. 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. 20. 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. 21. 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. 22. 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. 23. 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. Page 5 of 9 C :,,fr...x COLORADO Air Pollution Control Division cDPNE Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 24. 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. 25. 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: Carissa Money 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 three (3) HLP separators at an existing well production facility. Page 6 of 9 .x COLORADO 184- Air Pollution Control Division Department of Public Health hi 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 782 39 Toluene 108883 565 28 Ethylbenzene 100414 23 1 Buffer 006 Xylenes 1330207 163 8 n-Hexane 110543 6,685 334 2,2,4- 540841 2 0 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 006: Weight Uncontrolled Controlled CAS # Pollutant Compostion of Emission Emission Source the Gas (%) Factors Factors (lb/MMSCF) (lb/MMSCF) NOx NA 134.12 134.12 AP-42 Page 7 of 9 C,. :,.-4.... 4hdlovii Air Pollution Control Division Department of Public Health b Env ronment Dedicated to protecting and improving the health and environment of the people of Colorado Weight Uncontrolled Controlled CAS # Pollutant Compostion of Emission Emission Source the Gas (%) Factors Factors (lb/MMSCF) (lb/MMSCF) CO NA 611.43 611.43 AP-42 VOC 60.0 54,780 2,739.0 Gas Analysis 71432 Benzene 0.13 118.94 5.9470 Gas Analysis 108883 Toluene 0.09 85.962 4.2981 Gas Analysis 1330207 Xylene 0.03 24.756 1.2378 Gas Analysis 110543 n-Hexane 1.11 1017.0 50.8512 Gas Analysis 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 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 02/05/2020. The weight % values and molecular weight(34.6225 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 NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 emission factors by a higher heating value of 1,972.3 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 cornbustor(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/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Page 8 of 9 C :< COLORADO WAir Pollution Control Division . Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories , MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Hydrocarbon Liquid Loading APEN �., R�lM�M Form APCD-208 4,04) .. CDDHE Air Pollutant Emission Notice (APEN) and ?� Application for Construction Permit _'o t� All sections of this APEN and application must be completed for both new and existing facilities, including APEN 'a' updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 16WE0033 AIRS ID Number: 123 / 9E3E /001 Wanly iral Apil) !; i ac1 ed a permit aru A n,rUl Section 1 -Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Grant Hurt 14H-G268 Battery Site Location Site Location: SWNE Section 14, T2N, R68W 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. 4294G3 ase,COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 12/2019 1 .. Page 18 of 89 Permit Number: 16WE0033 AIRS ID Number: 123 /9E3E/001 `Lea'.e Liank u.nl,, s APCD ha,ahead,/ass,rnd a perms and AIRS IDI Section 2 - Requested Action O NEW permit OR newly-reported emission source 0 Request coverage under construction permit 0 Request.coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 Q 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- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info a Notes: Modify permit with a reduced throughput, emissions and APCD emission factors. 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Truck loadout of condensate from tanks Company equipment Identification No. (optional): LOAD-1 For existing sources, operation began on: 4/9/2015 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? ✓❑ Yes O No Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes IJ No emissions? Does this source load gasoline into transport vehicles? 0 Yes 0 No Is this source located at an oil and gas exploration and production site? 0 Yes 0 No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual Yes 0 No average? Does this source splash fill less than 6,750 bbl of condensate per year? O Yes El No Does this source submerge fill less than 16,308 bbl of condensate per year? 0 Yes El No COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 12:2019 2 ;�/�►�! „ Page 19 of 89 Permit Number: 16WE0033 . AIRS ID Number: 123 /9E3E/001 [Led' ',tank unI ss APC0 Ct s,aI eddy assigre a pecin t ae,d AIRS:DI Section 4 - Process Equipment Information Product Loaded: '❑ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 52,925 bbl/year Actual Volume Loaded: 55,013.42 bbl/year This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars"or"tank trucks") — If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: Average temperature of F bulk liquid loading: Molecular weight of True Vapor Pressure: Psia @ 60 °F lb/lb-mot displaced vapors: If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loadeds: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ( ft3/truckload 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. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.1406661-104.966341 ❑� Check box if the following information is not applicable to the source because emissions will not be emitted • from a stack. If this is the case, the rest of this section may remain blank. Operator Discharge Height Above Temp Flow Rate Velocity Stack iD No. , 'Ground Level(Feet) e1) (ACFM)' , (ftlaec) 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): o Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other(describe): COLORADO H Form APCD-208 ydrocar bon Liquid Loading APEN Revision 12,2019 3 I �i> Page 20 of 89 Permit Number: 16WE0033 AIRS ID Number: 123 /9E3E/001 {Leave blank.unless AP(D nos ulreadv assgnnd a peer : a ci A:P.S IDI 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: % Used for control of: VOC,HAPs Rating: NA MMBtu/hr Combustion Type: Enclosed Combustor Make/Model: TBD Device: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: NA 'F Waste Gas Heat Content: 2,565 Btu/scf Constant Pilot Light: (] Yes ❑ No Pilot Burner Rating: 0 025 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑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 SO. NOx CO VOC Enclosed Combustor 100% 95% HAPs Enclosed Combustor 100% 95% Other: I] Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane 0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 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 (A42, Emissions Emissions6 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx 0.068 Ib/MMBtu AP-42 -- 0.02 -- 0.02 CO 0.31 Ib/MMBtu AP-42 -- 0.09 - 0.06 VOC 0.236 IbTbl APCD 8.94 0.45 6.25 0.31 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. COLORADO Form APCD-208 Of()carbon Liquid Loading APEN Revision 12,2019 4 Page 21 of 89 • Permit Number: 16WE0033 AIRS ID Number: 123 /9E3E/001 [Leave btank.n;ie55 APED has atrea ie1 a pern a, r art AIPa ID! 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 0.00041 lb/bbl APCD 171 883 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n-Hexane 110543 0 0036 Ibibbl APCD 418 20 91 2,2,4-Trimethylpentane 540841 Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 4/22/2020 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 Ei Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 12/2019 5 I le*, 2.741:4 Page 22 of 89 r Condensate Storage Tank(s) APEN C 4k.Alr," Form APCD-205 APR CDPHE Air Pollutant Emission Notice (APEN) and 4 Application for Construction Permit ,„ 2aZ64 S`' All sections of this APEN and application must be completed for both new and existing facilities, including APEN .`m4, All 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. 002, Permit Number: 2O UUs Q4g-c1 AIRS ID Number: 123 / 9E3E /4304 CD h3ti 8:r .)cl assi ned a Permit irr and AIRS O1 Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Grant Hurt 14H-G268 Battery Site Location:• Site Location SWNE Section 14, T2N, R68W 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 Addressz: 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. 429461 ..COLORADO Form APCD-2O5 Condensate Storage Tank(sr APEN Revulon 12:2019 1 I NIP !°""°.u": sea Page 5 of 89 Permit Number: AIRS ID Number: 123 /9E3E/001 [Leave blank unless APCD has already assigned a pore nt , and AIRS ID] Section 2 - Requested Action NEW permit OR newly-reported emission source Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: Request conversion from GP01 to an individual 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: 4/9/2015 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: [] Exploration&Production(E&P)site ❑ Midstream or Downstream (non E&P)site Wilt this equipment be operated in any NAAQS nonattainment area? Q Yes O No Are Flash Emissions anticipated from these storage tanks? Yes O No Is the actual annual average hydrocarbon liquid throughput≥500 bbl/day? O 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 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 121 No emissions≥6 ton/yr(per storage tank)? COLORADO Form ARID 205 Condensate Storage Tank(5)APEN Revision 12//01 2I a®� ..." Page 6 of 89 Permit Number: AIRS ID Number: 123 /9E3E/001 )Leave b[ii0ker_. >;f`,PCD Pas already a;eign d a permit anti AIRS ID] r Section 4 Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbUyear) Condensate Throughput: 55,013 52,925 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 58.8 degrees RVP of sales oil: 12.2 Tank design: ❑✓ Fixed roof ❑ Internal floating roof ❑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 8 4000 4/2015 4/2015 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 38088 Grant Hurt 1A-14H-G268 0 05 - 123 - 38089 Grant Hurt 1B-14H-G268 0 05 - 123 - 38091 Grant Hurt 1C-14H-G268 0 05 • 123 - 38090 Grant Hurt 1D-14H-G268 O 05 - 123 - 38092 Grant Hurt 1E-14H-G268 0 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all 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) 40.140666/-104.966341 ❑� Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) Indicate the direction of the stack outlet: (check one) ❑Upward ❑Downward 0 Upward with obstructing raincap ❑Horizontal ❑Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): p COLORADO Form APCD-1105 Condensate Storage Tank(s) APEN - Recision IL1?G19 3 ti Page 7 of 89 Permit Number: AIRS ID Number: 123 /9E3E/001 [Leave htank unless APCD has alreac:y ass g led a permit Y.sad AIRS ID) Section 6- Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O 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 O Combustion Requested Control Efficiency: 95 % Device: 2,545 btu/scf Manufacturer Guaranteed Control Efficiency: 98 % CDM 10/13/2020 Minimum Temperature: NA Waste Gas Heat Content: 2.565 Btu/scf Constant Pilot Light: ❑� Yes ❑ No Pilot Burner Rating: 0.025 MMBtu/hr 0.2 MMBtu/hr Description of the closed loop system: O Closed Loop System Pollutants Controlled: o Other: Description: Control Efficiency Requested: % Section 7- Gas/Liquids Separation Technology Information (E(tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 45 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. ge,COLONADO Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 4 Page 8 of 89 Permit Number: AIRS ID Number: 123 /9E3E/001 [Leave braid,unless ALLC his already assigned a:?er--it C and ANS 101 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): Pollutant Control Equipment Descri Description Collection Efficiency Control Efficiency p (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC Enclosed Combustor(ECD) 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: Emission Factor? Actual Annual Emissions Requested Annual Permit Pollutant Emission Limit(s)5 Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units (AP 42, Emissions Emissions8 Emissions Emissions Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 13:76 1;.06 lb/bbl Site Specific 17 01 0.85 364,02.345.6 18.21 17.3 NO. 0068 lb/MMBtu AP-42 — 0.02 -- 6.--59 0.7 CO 0,31 lb/MM9tu AP-42 -- 0.11 -- 2,67 3.1 5 Requested values will become permit limitations or wilt be evaluated for exempt status,as applicable, and should consider Red-lined by future process growth. Requested values are required on all APENs,including APEN updates.future 7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site 11/12/2020 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 9 No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units Basis (AP-42, Emissions Emissions8 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 2.71E-02 lb/bbl Site specific 99 5 Toluene 108883 2.01E-02 lb/bbi Site Specific 253 13 Ethylbenzene 100414 681E-04 lb/bbi Site Specific 33 2 Xylene 1330207 4.37E-03 lb/bbl Site Specific 154 8 n-Hexane 110543 2_24E-01 lb/bbi Site Specific 1,452 73 2,2,4-Trimethylpentane 540841 2.67E-04 lb/bbl Site Specific 50 2 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. COLORADO Form APC C-205 Condensate Storage Tank(s)APEN - Revision 12:.:2019 5 I �°"a.� Page 9 of 89 Permit Number: AIRS ID Number: 123 /9E3E/001 heave t t,nrt irra ss APC r t 3ii=-ra , as;;n d a parmi. `and AIRS frDI 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. 4/22/2020 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: El Draft permit prior to issuance Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver,CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APED 205 Condensate Storage Tankrsr APED Re Osi�n t 2-L01 6 N' ..." '.` Page 10 of 89 • . Gas Venting APEN - Form APCD-211` I! -f,' � 4 Air Pollutant Emission Notice (APEN) and CDPHE 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: 20w 6.04610 AIRS ID Number: 123 /9E3E / Q C U L,-)o t-hnl<_mic,s ACE) !Dt Section 1 - Administrative Information • Company Name': Crestone Peak Resources Operating, LLC Site Name: Grant Hurt 14H-G268 Battery Site Location Site Location: SWNE Section 14, T2N, R68W Weld County: NAICS or SIC Code: 1311 Mailing Address: 10188 East 1-25 Frontage 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. 429464 :COLOR ADO Form APCD-211 Gas Venting;APEN - Revision 12,2019 1 I :COLOR: Page 23 of 89 Permit Number: AIRS ID Number: 1 23 /9E3E/ [Leave 1,1;1[1:rini>>;APCD has atre:arty ow‘,Tted a perr rt and AiR.S ID] Section 2 - Requested Action O 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 O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: 3 Company Name Change Certification Form (Form APCD-106)must be submitted. For company name change,a completed C p y a g 4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. II 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 Q 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 Yes ❑ No nonattainment area? Is this equipment located at a stationary source that is O Yes Q No considered a Major Source of(HAP)Emissions? Is this equipment subject to Colorado Regulation No. 7, 0 Yes ❑ No Section XVII.G? COLORADO Form APCD-211 1 Gas Venting APEN Revision 12 2019 2 I ISOPage 24 of 89 II Permit Number: AIRS ID Number: 1 23 /9E3E/ [Lt-,we blank+nles5 APED f iy assigned a permit '?•md A,RS IDj Section 4 - Process Equipment Information r❑ 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 O 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? ❑✓ Yes O No Vent Gas 972 BTU/SCF Gas Venting Heating Value: Process Parameters: Requested: 6.57 MMSCF/year Actual: __ MMSCF/year -OR- . Liquid Throughput Requested: bbl/year Actual: bbl/year Process Parameters Molecular Weight: 34.6225 VOC (Weight%) 59.9655 Benzene (Weight%) 0.1302 Vented Gas Toluene (Weight%) 0.0941 Properties: Ethylbenzene (Weight%) 0.0039 Xylene (Weight%) 0.0271 n-Hexane (Weight%) 1.1133 2,2,4-Trimethylpentane (Weight%) 0.0004 Additional Required Documentation: 0 Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX Et 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. RC :COLORADO Fc,rr API 211 Gas Venting APEN - Revision 12,2�?9 3 ', ;.. Page 25 of 89 Permit Number: AIRS ID Number: 123 /9E3E/ (Lens-r I i,,r_unless APCD - n1rca v ass;ned a rrer;nit-'and AIRS ID Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.140666/-104.966341 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 Aiwve Ground Level Temp, Flow'Rate Velocity Stack 1D No. en saw) otheo =feet) Indicate the direction of the stack outlet: (check one) ❑ Upward O Downward O Upward with obstructing raincap ❑ 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): ❑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: TBD Combustion Requested Control Efficiency: 95 % Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Unknown Waste Gas Heat Content: 1,972 Btu/scf Constant Pilot Light: Yes ❑ No Pilot burner Rating: 0.025 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: go,% COLORADO Form APCD-211 Gas Venting, 2 APEN - Revision 12019 4 Page 26 of 89 Permit Number: AIRS ID Number: 1 23 /9E3E/ Leave tdsnk unless APCD Isar already assigned a pee nil. f and AIRS ID] 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? El 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 SO. _ NO„ CO VOC Enclosed Combustor 100% 95% HAPs Enclosed Combustor 100% 95% Other: From what year is the following reported actual annual emissions data? -- 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 ;2' Emissions Emissions° Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NO. 0.068 Ib/MMBtu AP-42 -- — -- 0.45 CO 0.31 lb/MMBtu AP-42 -- -- -- 2.04 VOC 54,780 lb/MMscf Site Specific -- -- 180.04 9O0 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-criteriaEj Yes O No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled Service(CAS) Basis Units (AP-42, Emissions Emissions° Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 118 94 lb/MMscf Site Specific 782 39.09 Toluene 108883 85.96 lb/MMscf Site Specific 565 28.25 Ethylbenzene 100414 3.56 Ib/MMscf Site Specific 23 1.17 Xylene 1330207 24.76 lb/MMscf Site Specific 163 8.14 n-Hexane 110543 1,017 Ib/MMscl Site Specific 6,685 334 2,2,4-Trimethylpentane 540841 0.34 Ib/MMscf Site Specific 2 0.12 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 °""°'2. :` Page 27 of 89 Permit Number: AIRS ID Number: 1 23 i 9E3E/ (Leave blank APCD ha 3[,e-u d{assigned a port-nit Tiand AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. t t �' , r ' 4/22/2020 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: El Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 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-2 I 1 Ga-s Venting MIN - Revision 12 2019 6 I „ Page 28 of 89 Hello