HomeMy WebLinkAbout20202137.tiff a --4. COLORADO
Y.51 Department of Public
` Health&Environment
Weld County - Clerk to the Board RECEIVED
1150 O St
PO Box 758
Greeley, CO 80632 MAY 18 2020
May 7, 2020 WELD COUNTY
C0MMISSI0NER S Dear Sir or Madam:
On May 8, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
Crestone Peak Resources Operating, LLC - Davis 9H-G266 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 a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ti
Jared Polls,Governor I Jilt Hunsaker Ryan,MPH, Executive Director I ,, .,: <,.k„;*i:
Pib 1; C (Zev;e c,J CC:FL(TP)� NL(uS)PW(smiER/cH/cw),
o&(sK) 2020-2137
07/22/2O O7/1512°
a441-4I:MrM,M Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: Crestone Peak Resources Operating, LLC - Davis 9H-G266 Battery - Weld County
Notice Period Begins: May 8, 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: Davis 9H-G266 Battery
Exploration Et Production Well Pad
SWNE SEC 9 T2N R66W
Weld County
The proposed project or activity is as follows: Applicant proposes to transfer condensate tank battery from
GP01 coverage to coverage under an individual permit, while retaining the previously approved site specific
emission factors.
Without federally enforceable permit limitations for XP and XA sources, this facility became an existing
major source of Nox and VOC upon re-designation of DMNFR NAA on 1/27/2020. With this permitting action,
the operator is requesting a new synthetic minor permit limit for VOC, and this project will therefore
require Public Comment.
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 20WE0306 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:
Ben Fischbach
'COLORADO
1 I
D arnment rimue
Fdettth6 Environznez t
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
2 (COLORADO
4.
Department of Pubic
Health 6 Environment
Condensate Storage Tank(s) APENaForm APCD-205 Y
CDPHE Air Pollutant Emission Notice (APEN) and `
Application for Construction Permit X'
AU sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal Your APEN will be rejected if it is filled
out incorrectly,is missing information,or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category,there may be a more specific APEN available for your source(e.g.
crude oil storage tanks, produced water storage tanks,hydrocarbon liquid loading,etc.). In addition,the General
APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term,or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 2 WE O 6) AIRS ID Number: 123 /9B2A/001
[Leave blank unless APCD has already assigned a permit g and AIRS ID]
Section 1 -Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Davis 9H-G266 Battery
Site Location
Site Location:
SWNE Section 9, T2N, R66W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10188 East I-25 Frontage Road
Firestone, CO 80504 Contact Person: Sabrina Pryor
Phone Number. (303) 774-3923
E-Mail Address2: sabrina.pryor@crestonepr.com
'Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
426309
COLORADO
Form APCD-205 Condensate Storage Tanks) APEN Revision 12/2019 1 9 IOW , d",
Permit Number: •
PAIRS ID Number: 123 /9B2A/001
[Leave blank unless APCD has already assigned a permit#and MRS ID]
Section 2- Requested Action
Q NEW permit OR newly-reported emission source
51 Request coverage under traditional construction permit
Request coverage under a General Permit
O GP01 O GPO8
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 name;
❑ Change permit limit O Transfer of ownership4 O Other(describe below)
-OR
• APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info a 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: 08/09/2012
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: O Exploration It Production(MP)site O Midstream or Downstream(non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? 151 Yes O No
Are Flash Emissions anticipated from these storage tanks? 5 Yes O No
Is the actual annual average hydrocarbon liquid throughput z 500 bbl/day? p Yes O No
If"yes",identify the stock tank gas-to-oil ratio: 4.07 m3/liter
Are these storage tanks subject to Colorado.Oil and Gas Conservation Commission(COGCC) p Yes ❑ No
805 series rules?If so, submit Form APCD-105.
Are you requesting t 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual p Yes O No
emissions z 6 ton/yr(per storage tank)?
COIO*AOO
Form APCD-2O5 Condensate Storage°'ankis) APEN • Revision 12/2019 2 ? �
•
Permit Number: AIRS ID Number: 123 /9B2A/001
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 4-Storage Tank(s) information
Actual Annual Amount Requested Annual Permit Limit'
(bbl/year) (bbUyeor)
Condensate Throughput: 728,840 392,375
From what year is the actual annual amount? 2019
Average API gravity of sates oil: 49.3 degrees RVP of sales oil: 7.3
Tank design: 0 Fixed roof 0 Internal floating roof 0 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
Obi) Storage Tank(month/year) (month/year)
TANKS 8 4,000 11/2018 08/2012
Wells Serviced by this Storage Tank or Tank Battery'(LAP Sites Only)
API Number Name of Well Newly Reported Well
05 • 123 - 35365 Davis 1A-9H 0
05 - 123 - 35421 Davis 1B-9H 0
05 - 123 - 35366 Davis 1C-9H 0
05 - 123 - 46587 Davis 1D-9H-G266 ❑
05 - 123 - 46510 Davis 1E-9H-G266 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 alt APENs,including APEN updates.
'The EEP 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 UM)
40.154583/-104.777786
rA 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 ❑Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
o Other(describe):
COLORADO
Form APCD-2O5 Condensate Storage Tanks? APEN Revision 12/2019 3 lair/ :=7"411,,.....'
Permit Number: AIRS ID Number: 123 /9B2A/001
[Leave blank unless APCD has atreaCy assigned a permit and AIRS ID]
Section 6 -Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
❑ Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed(emissions vented):
Pollutants Controlled: VOCs, HAPs
Rating: NA MMBtu/hr
Type: Enclosed Combustor Make/Model: NA
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98 % 3,076 -BF
Minimum Temperature: NA Waste Gas Heat Content: 2,838 Btu/scf 5/5/20
Constant Pilot Light: r4 Yes O No Pilot Burner Rating: 0.025 MMBtu/hr Per
attached
email
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7- Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 3.0 psig
Describe the separation process between the welt and the storage tanks: Wellhead production to
high-low pressure separators, bulk gas from separators to sales, bulk water from separators to
tanks, bulk condensate from separators to vapor recovery tower, and then to storage tank battery.
Produced water to storage tank battery.
COLORADO
Form APCD-2O5 Condensate Storage Tankisi APEN Revision 12/2019 4 I ,
Permit Number: AIRS ID Number: 123 /9B2A/001
[Leave blank unless APCD has already assigned a permit 4 and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form?.
Is any emission control equipment or practice used to reduce emissions? ® Yes O No
If yes,describe the control equipment AND state the collection and control efficiencies(report the overall,or
combined,values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (x of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC Enclosed Combustor(ECO) 100% 959E
NOx
CO.
HAPs Enclosed Combustor(ECD) 100% 95%
Other.
From what year is the following reported actual annual emissions data?
2019
Use the following table to report the criteria pollutant emissions from source:
RequeEmission Factor? Actual Annual Emissions Emission
Permit
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP 42, Emissions Emission, Emissions Emissions
Basis Alfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
VOC 1.0087 SON Site Specific 659.1 330 354.8 17.7 -BF
NOx 0.068 Btu AP 42 — 0.9. 1.1 — 0i 0.6 5/5/20
bM
Per attached email
CO 0.31 Ib/MMBtu AP-42 — 42 4.8 24 2.6
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth.Requested values are required on all APENs,including APEN updates.
7 Attach 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.
e Annual emission fees will be based on actual controlled emissions reported.If source has not yet started operating,provide
projected emissions:
Section 9- Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes O No
pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 25O lbs/year?
If yes,use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor? Actual Annual Emissions
Abstract Source Uncontrolled Controlled
Chemical Name service ) Uncontrolled Units (AP-42, Emissions Emissionsa
Bash
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.0083 crow _ Site Semitic 6062.2 303.1
Toluene 108883 0.0113 Rdbw Site Specific 8271.0 413.5
Ethylbenzene 100414 00004 crow Site Specific 326.6 16.5
Xylene 1330207 0.0043 crow see Specific 3107.3 155.4
n-Hexane 110543 0.0666 crew Site Specific 49991.4 2499 6
2,2,4-Trimethylpentane 540841 0.0003 _ rolow site Specific 2388 11.9
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 APCD-2O5 Condensate Storage Tanks( APEN - Revision 12/2019 5 1 Illikilif ,=u 1 .
Permit Number: AIRS ID Number: 123 /9B2A/001
Section 10- Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and wilt be operated in full compliance with each condition of the applicable General Permit. •
2/28/2020
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:
Draft permit prior to issuance
QQ 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
Agawam COLORADO
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: Crestone Peak Resources Operating,LLC
Source Name: Davis 9H-G266
Emissions Source AIRS ID2: 123/9B2A/001
Wells Services by this Storage Tank or Tank Battery(E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-46520 Davis 1F-9H-6266 0
05-123-46507 Davis IG-9H-G266 0
05-123-46512 Davis 1H-9H-G266 0
05-123-46746 Davis 11-9H-G266 0
05-123-46508 Davis 1J-9H-G266 0
05-123 46517 Davis 1K-9H-G266 0
05-123-46681 Davis 1L-9H-G266 0
05-123-46519 Davis 1M-9H-G266 0
05-123-46506 Davis 1N-9H-6266 0
05-123-46504 Davis 1O-9H-G266 ❑
05-123-46503 Davis IP-9H-G266 0
05-123-46511 Davis 1Q-9H-G266 0
05-123-46505 Davis IR-9H-G266 ❑
OS-123-46513 Davis 1S-9H-G266
05-123-46516 Davis IT-9H-G266 0
- - 0
0
0
0
0
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter
N/A
Form APCD-212 B2-APEN FORM 212-Wellsite Addendum(TANKS)
- -... COLORADO
Air Pollution Control Division
CDPH
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0306 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Davis 9H-G266 Battery
Plant AIRS ID: 123/9B2A
Physical Location: SWNE SEC 9 T2N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
TANKS 001 Eight (8) 500 barrel fixed roof storage Enclosed Flare
vessels used to store condensate
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. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. 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
Page 1 of 10
a .�;.,. COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. 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.)
4. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO. VOC CO Type
TANKS 001 --- --- 17.7 2.6 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
6. 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.
7. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission
calculations must be made available to the Division for inspection upon request. For the
purposes of this condition, insignificant activities are defined as any activity or equipment,
which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is
permit exempt. (Regulation 3, Part C. II.E.)
Page 2 of 10
•x•~•M- COLORADO
4r0_,/! Air Pollution Control Division
CDPME
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TANKS 001 Enclosed Flare VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS
Equipment Process Parameter Annual Limit
ID Point
TANKS 001 Condensate throughput 392,375 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. 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
Page 3 of 10
a ,., - COLORADO
4"k=411 Air Pollution Control Division
CDFHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
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 £t MAINTENANCE REQUIREMENTS
17. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
Page 4 of 10
C • •x- COLORADO
41":1,?-4° Air Pollution Control Division
COPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen-minute period during normal
operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23)
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
Number Emission Point New Emission Point
GP01 123/9B2A/001 123/9B2A/001
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
Page 5 of 10
COLORADO
4'44— ti Air Pollution Control Division
CDPHE
Department of Public Health fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. This source is subject to the provisions of Regulation Number 3, Part C, Operating Permits (Title
V of the 1990 Federal Clean Air Act Amendments). The provisions of this construction permit
must be incorporated into the Operating Permit. The application for the modification to the
Operating Permit is due within one year of the effective date of reclassification of the Denver
Metro/North Front Range (DMNFR) area of Colorado from "Moderate" to a "Serious"
nonattainment area (NAA) for ozone (i.e. due by January 27, 2021).
23. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
24. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
25. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C,R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
26. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
27. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
28. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by-the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
29. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
30. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Crestone Peak Resources Operating,
LLC. This new permit replaces an existing GP01
for the same equipment. Facility is major for
NOx, and Synthetic Minor for VOC.
Page 7 of 10
is �-'',. COLORADO
Air Pollution Control Division
n. CDPHE
Department of Pubhc 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 3,264 163
Toluene 108883 4,453 223
Ethylbenzene 100414 176 9
001 Xylenes 1330207 1,673 84
n-Hexane 110543 26,913 1,346
2,2,4-
540841 128 6
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:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 2.90 * 10-3 2.90 * 10-3
CO 1.32 * 10-2 1.32 * 10-2 CDPHE
VOC 1.8087 0.0904
71432 Benzene 8.318 * 10-3 4.159 * 10-4 ProMax
Page 8 of 10
..1 COLORADO
Air Pollution Control Division
CACDPHE
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
108883 Toluene 1.135 * 10-2 5.674 * 10-4
100414 Ethylbenzene 4.481 * 10"4 2.241 * 10-5
1330207 Xylene 4.263 * 10-3 2.132 * 10-4
110543 n-Hexane 6.859 * 10-2 3.43 * 10-3
540841 2'2'4 3.274 * 10-4 1.637 * 10-5
Trimethylpentane
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated •
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Major Source of: NOx
Synthetic Minor Source of: VOC, n-Hexane, Total HAPs
PSI) Major Source of: NOx
Synthetic Minor Source of: VOC
NANSR Major Source of: NOx
Synthetic Minor Source of: VOC
MACT HH Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A- Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA- Subpart DDD
Page 9 of 10
ar:M- COLORADO
7_•t1 Air Pollution Control Division
CDPME
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Ben Fischbach
Package #: 426311
Received Date: 2/28/2020
Review Start Date: ` 7/2020
Section 01 - Facility Information
Company Name: Crestone Peak Resources Operating, LLC Quadrant Section Township Range
County AIRS ID: 123 SWNE ? 2N 66
Plant AIRS ID: 9B2A
Facility Name: Davis 9H-G266 Battery
Physical
Address/Location: SWNE quadrant of Section 9, Township 2N, Range 66W
County: Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
Permit #
AIRS Point #
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned
Transferrin[:
Permit Initial from GP01,
001 Condensate Tank TANKS 20WE0306 Issuance retaining SSEF,
Section 03 - Description of Project
Applicant proposes to transfer condensate tank battery from GP01 coverage to coverage under an individual permit, while retaining the previously approved site
specific emission factors.
Without federally enforceable permit limitations for XP and XA sources, this facility became an existing major source of Nox and VOC upon re-designation of DMNFR
NAA on 1/27/2020. With this permitting action, the operator is requesting a new synthetic minor permit limit for VOC, and this project will therefore require
PubCom.
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 for PSD or NANSR
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 Fl nTSP HAPs
Prevention of Significant Deterioration (PSD) ..,� J
Title V Operating Permits (OP) ►---4 El
Non-Attainment New Source Review (NANSR) •
Is this stationary source a major source? Y'e:
If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) _
Title V Operating Permits (OP) J , .
Non-Attainment New Source Review (NANSR) J
Condensate Storage Tank(s) Emissions Inventory
Section 01 - Administrative Information
982A
Facility AIRs ID:
County Plant Pont
Section 02 - Equipment Description Details
Detailed Emissions Unit Eight (8) 500 bbl Condensate Storage Tanks
Description:
Emission Control Device ECD
Description:
Requested Overall VOC & HAP Control Efficiency %: 95.0
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput = 728,840.0 Barrels (bbl) per year
Requested Permit Limit Throughput = 392,375.0 Barrels (bbl) per year Requested Monthly Throughput = 33325.0 Barrels (bbl) per month
Potential to Emit (PTE) Condensate
Throughput = 392,375.0 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = .3076.0 Btu/scf 0.05747883 mmscfd 57478.83 scfd
Volume of waste gas emitted per BBL of
liquids produced = 13.7 scf/bbl 4201.131429 bbl/day
Actual heat content of waste gas routed to combustion device = 30,673.3 MMBTU per year 13.68175
Requested heat content of waste gas routed to combustion device = 16,513.1 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 16,513.1 MMBTU per year
Control Device
Pilot Fuel Use Rate: 25 scfh 0.2 MMscf/yr
Pilot Fuel Gas Heating Value: 1000 Btu/scf 219.0 MMBTU/yr
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (Ib/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 1.8087 0.0904 '
Benzene 8.318E-03 4.159E-04
Toluene 1.135E-02 5.674E-04 . . r ,
Ethylbenzene 4.481E-04 2.241E-05 ., ;~:
Xylene 4.263E-03 2.132E-04 . . : s:
n-Hexane 6.859E-02 3.430E-03 ,
224 TMP 3.274E-04 1.637E-05 _ i .
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 0.0003 ,,fir:`
PM2.5 0.0075 0.0003 .,-
NOx 0.0680 0.0029
CO 0.3100 0.0130
-
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source
(Waste Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 7.4510 A;-'•42. `saa; a..-x „ W:43 , P;. .
PM2.5 0.0075 7.4510 AP-42 Table 1.4-2 (P ``10/P54. . ;?
NOx 0.0680 68.0000 AP-42 Chapttr 13.:4 1ndustcia Fi.:i e::: li`Ni ';
CO 0.3100 310.0000 AP-42 Chapter 13.5 fr'sduatrlat Fi -i,st:,,r (CO.1 ,
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) (lbs/month)
VOC 354.8 659.1 33.0 354.8 17.7 3013.8
PM10 0.1 0.1 0.1 0.1 0.1 10.6
PM2.5 0.1 0.1 0.1 0.1 0.1 10.6
NOx 0.6 1.1 1.1 0.6 0.6 96.6 2.90E-03
CO 2.6 4.8 4.8 2.6 2.6 440.5 1.32E-02
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 3264 6062 303 3264 163
Toluene 4453 8271 414 4453 223
Ethylbenzene 176 327 16 176 9
Xylene 1673 3107 155 1673 84
n-Hexane 26913 49991 2500 26913 1346
224 TMP 128 239 12 128 6
2 of 7 K:\PA\2020\20WE0306.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section Xll.C-F
Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart OOOO Storage tank is not subject to NSPS OOOO.
NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a
Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
• '
Does the company use the state default emissions factors to estimate emissions?
>
a ..�". `3. o' .^iii.
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? ' :'_ 1 ;1
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which generally means site-specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site-specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
This permit is based on SSEFs which were previously approved in the last GP01 issuance for this point (2019). While reviewing this application, I noticed that the pressurized liquid stream in the original
model (used to develop the SSEFs) was specified based on the gauge temperature (rather than the probe temperature) listed on the pressurized liquid sample analysis results. Per a training deliviered by
a former division engineer (who previuously worked in sampling), the probe temperature and pressure are almost always more accurate than the gauge T and P, and should be used in modeling to
properly represent the pressurized liquid sample thermodynamics properties. I reached out to operator concerning this and requested an updated model based on probe results for P and T. Operator
provided me with a Promax model that was updated to refelct my requests, and I was able to verify that the previously approved emission factors are conservative, and therefore aceeptable for
permitting. Operator's model also listed an "oil flash factor" of 13 scf/bbl, though this value excluded vapors from W&B emissions. Including W&B vapors brings the GOR to 13.6 scf/bbl.
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point # Process # SCC Code Pollutant Factor Control % Units
h 01 PM10 0.01 0 lb/1,000 gallons condensate throughput
PM2.5 0.01 0 lb/1,000 gallons condensate throughput
NOx 0.07 0 lb/1,000 gallons condensate throughput
VOC 43.1 95 lb/1,000 gallons condensate throughput
CO 0.31 0 Ib/1,000 gallons condensate throughput
Benzene 0.20 95 lb/1,000 gallons condensate throughput
Toluene 0.27 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput
Xylene 0.10 95 lb/1,000 gallons condensate throughput
n-Hexane 1.63 95 lb/1,000 gallons condensate throughput
224 TMP 0.01 95 lb/1,000 gallons condensate throughput
•
3 of 7 K:\PA\2020\20WE0306.CP1
Condensate Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re ulation 3 Parts A and B-APEN and Permit R uirements
Source is in the Non-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 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 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section 11.0.3)7
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 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)? iV0 Go to next question
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section 11.0.2)7 YRS ' Source Requires a permit
Source requires a permit
Colorado Regulation 7,Section XII.C-F
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue - You have indicated th
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? Yes Continue -You have indicated th
3. Is this storage tank located upstream of a natural gas processing plant? Yes ' Source is subject
Storage tank is subject to Regulation 7, Section XII.C-F
Section XII.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Section XII.D—Emissions Control Requirements
Section XII.E— Monitoring
Section XII.F— Recordkeeping and Reporting
Colorado Regulation 7,Section XII.G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area? Yes Continue -You have determined
2. Is this storage tank located at a natural gas processing plant? No Storage Tank is not subject to Re
3. Does this storage tank exhibit"Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC7 Yes` . Source is subject
Storage Tank is not subject to Regulation 7, Section XII.G
Section XII.G.2- Emissions Control Requirements
Section XII.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Colorado Regulation 7,Section XVII
1. Is this tank located at a transmission/storage facility? No Continue-You have indicated th
2. Is this condensate storage tank' located at an oil and gas exploration and production operation ,well production facility?, natural gas compressor stations or natural gas processing plant? Yes Go to the next question -You ha
3. Is this condensate storage tank a fixed roof storage tank? Yes • Go to the next question
4. Are uncontrolled actual emissions'of this storage tank equal to or greater than 6 tons per year VOC? Yes . Source is subject to parts of Reg'
Storage tank is subject to Regulation 7,Section XVII, B, C.1& C.3
Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only"stabilized" liquids? Source is subject to all provision:
Storage tank is subject to Regulation 7, Section XVILC.2
Section XVII.C.2- Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
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 (m3) (-472 BBLs)? Yes 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 NSPS
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 (-10,000 8514 used for petroleum' or condensate stored, processed, or treated prior to custody transfer2 as defined in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of"storage vessel"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b?
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 m3 ("950 BBL) and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.11ob(b))?; or
c The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 (-950 BBL) and stores a liquid with a maximum true vapor pressures 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 m3 (-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 M3 ("472 BBL] but less than 151 m3 (-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 Tank is not subject to NSPS Kb
40 CFR, Part 60,Subpart 0000/OOO0a,Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution
1. Is this condensate 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? Yes Continue - You have indicated th
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23. 2011 and September 18. 2015? No Storage Tank is not subject NSPS
3. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? Yes : Go to the next question
4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No, ; Storage Tank is not subject NSPS
5. Does this condensate storage vessel meet the definition of"storage vessel"2 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 HH?
Storage Tank is not subject to NSPS 0000a
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a 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 MALT 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: Yes 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 prior to 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 majors for HAPs? No 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"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage Tank is not subject to MACT HH
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
RACE 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.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Crestone_Peak Resources Operating, LLC
County AIRS ID 123 History File Edit Date 5'41202C
Plant AIRS ID 9B2A Ozone Status Non-Attainment
Facility Name Davis 9H-G266 Battery Last Modifed By: Ben Fischbach
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 67.5 1119.0 1 .1 82.7 57.2 0.0 0.0 0.0 0.0 1 .5 62.9 1 .1 24.2 0.0
Previous Permitted Facility total 0.0 0.0 0.0 0.0 1 .8 1115.4 1 .1 8.0 57.2 0.0 0.0 0.0 0.0 1 .8 59.3 1.1 8.0 2.9
•
001 20WE0306 Twelve 400 barrel storage tanks 0.6 354.8 2.6 18.3 0.6 17.7, 2.6 0.9 "oving from GP01 to individual permit, reduced
002 GP05 2- 500 bbl produced water tanks 0.2 133.9 1.1 14.8 0.2 10.0 1.1 0.7 No change
003 13WE1750 Condensate Loadout 0.2 106.3 0.8 0.2 0.2 5.3 0.8 0.0 No change
004 19WE0194 LP Separator Venting 0.3 99.5 1 .2 2.1 0.3 5.0 1.2 0.1 No change
005 19WE019S Fugitives 1 1 0 1 1 .1 0.1 No change
006 19WE0196.CN COMP-1 (46 HP NG RICE) 0.0 0.0 Cancellation received 2/28/2020 - no longer
exists.
007 19WE0197.CN COMP-2 (46 HP NG RICE) 0.0 0.0 Cancellation received 2/28/2020 - no longer
exists.
008 19WE0198.XP COMP-3 (46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0. 1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
009 19WE0199.XP COMP-4 (46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0. 1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
010 19WE0200.XP COMP-5 (46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
011 19WE0201 .XP COMP-6 (46 HP NG RICE) 0 0 0.0 7.3 0.4 8.3 0.1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
012 19WE0202.XP COMP-7 (46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
013 19WE0203.XP COMP-8 (46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0. 1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
014 19WE0204.XP COMP-9 (46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 , 0.1 0.0 0.0 0.9 0.4 1 .8 0.1 No change
0 0 0.0
0.0 0.0
APEN Exempt/Insignificants 0.0 0.0
XA Hi/Lo Separator Heaters (20) 0.3 0.3 4.3 0.20 3 6 0.1 0 3, 0.3 , - 4.3 0.20 3.6 0.1 Taken from Form 102
XA Bulk Heater Treater Heater (1) 0. 1 0. 1 0.8 0.0, 0.6 0.0 0.1 0.1 0.8 0.0 0.6 0.0 Taken from Form 102
FACILITY TOTAL 0.4 0.4 0.0 0.0 57.5 697.5 1.1 68.0 36.1 0.4 0.4 0.0 0.0 1.5 41.0 1.1 22.5 0.0 VOC: Syn Minor (NANSR and OP)
NOx: Major (NANSR and OP)
CO: True Minor (PSD and OP)
HAPS: Syn Minor n-hexane & total
Permitted Facility Total 0.0 0.0 0.0 0.0 1.3 694.5 1. 1 5. 7 35.5 0.0 0.0 0.0 0.0 1.3 38.0 1. 1 5.7 1.9 Excludes units exempt from permits/APENs
(O) Change in Permitted Emissions 0.0 0.0 0.0 0.0 -0.5 -21.3 0.0 -2.3 Pubcom required based on requesting new syn
minor VOC limit. Modeling not required based or
division guidance.
Total VOC Facility Emissions (point and fugitive) 60.4 Facility is eligible for GP02 because < 90 tpy
(A) Change in Total Permitted VOC emissions (point and fugitive) -21.3 _Project emissions less than 25 tpy
Without federally enforceable permit limitations for XP and XA sources, this facility became an existing major source of Nox upon re-designation of DMNFR NAA on 1/27/2020. With this permitting action, the operator is requesting a new synthetic minor permit limit for VOC,
Note 1 and this pojrect will therefore require PubCom.
Note 2
Page 5 of 7 Printed 5/5/2020
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 9B2A
Facility Name Davis 9H-G266 Battery
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 20WE0306 Twelve 400 barrel storage tanks 3264 4453 1673 26913 18.3
002 GP05 2- 500 bbl produced water tanks 7154 22484 14.8
003 13WE1750 Condensate Loadout 390 0.2
004 19WE0194 LP Separator Venting 349 160 3 2 '1 3679 2. 1
005 19WE0195 Fugitives 37 4 48 0. 1
006 19WE0196.CN COMP-1 (46 HP NG RICE) 0.0
007 19WE0197.CN COMP-2 (46 HP NG RICE) 0.0
008 19WE0198.XP COMP-3 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
009 19WE0199.XP COMP-4 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
010 19WE0200.XP COMP-5 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
011 19WE0201 .XP COMP-6 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
012 19WE0202.XP COMP-7 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
013 19WE0203.XP COMP-8 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
014 19WE0204.XP COMP-9 (46 HP NG RICE) 89 12 11 7 2 0 1 13 0. 1
0.0
0.0
A
APEN Exempt/Insignificants 0.0
XA Hi/Lo Separator Heaters (20) 0 0 155 0. 1
1
XA Bulk Heater Treater Heater (1 ) 0 0 27 0.0
0.0
TOTAL (tpy) 0.2 0.0 0.0 5.6 2.3 0.1 0.9 26.6 0.0 0.1 0.0 0.0 35.8
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
6 20WE0306.CP1 5/5/2020
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 9B2A
Facility Name Davis 9H-G266 Battery
Emissions with controls (lbs per year'
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 2.24 1-MP H2S TOTAL (tpy)
!Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 20WE0306 Twelve 400 barrel storage tanks 163 223 9 84 1346 0.9
002 GP05 2- 500 bbl produced water tanks 358 1124 0.7
003 13WE1750 Condensate Loadout 19.5 . 0.0
004 19WE0194 LP Separator Venting 17 8 1 184 0. 1
005 19WE0195 Fugitives = 37 48 0. 1
006 19WE0196.CN COMP-1 (46 HP NG RICE 0.0
007 19WE0197.CN COMP-2 (46 HP NG RICE) 0.0
008 19WE0198.XP COMP-3 (46 HP NG RICE, 89 12 11 2 0 1 13 0. 1
009 19WE0199.XP COMP-4 (46 HP NG RICE) 89 12 11 2 0 1 13 0. 1
010 19WE0200.XP COMP-5 (46 HP NG RICE) 89 12 11 2 0 1 13 0. 1
011 19WE0201 .XP COMP-6 (46 HP NG RICE 89 12 11 2 0 1 13 0. 1
012 19WE0202.XP COMP-7 (46 HP NG RICE) 89 12 11 2 0 1 13 0. 1
013 19WE0203.XP COMP-8 (46 HP NG RICE 89 12 11 2 0 1 13 0. 1
014 19WE0204.XP COMP-9 (46 HP NG RICE) 89 12 11 2 0 1 13 0. 1
0.0
0.0
APEN Exempt/Insignificants _ 0.0
XA Hi/Lo Separator Heaters (20) 0 155 0. 1
XA Bulk Heater Treater Heater (1 ) 0 27 0.0
0.0
TOTAL (tpy) 0.2 0.0 0.0 0.3 0.1 0.0 0.1 1 .4 0.0 0.0 0.0 0.0 2.2
7 20WE0306.CP1 5/5/2020
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