HomeMy WebLinkAbout20200629.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
October 7, 2020
Dear Sir or Madam:
RECEIVED
0CT 12 2020
WELD COUNTY
COMMISSIONERS
On October 8, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
Crestone Peak Resources Operating, LLC - Grant Salisbury Elmquist 14H -C268 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 in Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Potis, Governor Jill Hunsaker Ryan, MPH, Executive Director
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2020 - Q6 29
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Crestone Peak Resources Operating, LLC - Grant Salisbury Elmquist 14H -C268 Battery - Weld
County
Notice Period Begins: October 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: Grant Salisbury Elmquist 14H -C268 Battery
Exploration Et Production Well Pad
NENW SEC 14 T2N R68W
Weld County
The proposed project or activity is as follows: Applicant proposes the modification of the permits
15WE1413, 15WE1414, 15WE1415, and the permitting of a new separator venting point, covered under point
014 on permit 20WE0606.
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 15WE1413 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 Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
Zia
COLORADO
Department of Public
Health & Environment
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: 1 5WE1413
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 3
Crestone Peak Resources Operating, LLC
Grant Salisbury Elmquist 14H -C268 Battery
123/9E30
NENW SEC 14 T2N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TANKS
001
Twenty-six (26) 500 barrel fixed roof
storage vessels used to store condensate
Enclosed Flare
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 compliance as required by this permit may be obtained online at
Page 1 of 10
aktof444010
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III. E. )
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
TANKS
001
---
---
26.1
4.3
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
7. The owner or operator must use the emission 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.
Page 2 of 10
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
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
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TANKS
001
Enclosed Flare(s)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process
Process Parameter
Annual Limit
TANKS
001
01
Condensate throughput
95,630 barrels
02
Combustion of pilot light gas
0.22 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 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.
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. 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:
Page 3 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
• 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)
14. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section II, it
must be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or
by other convenient means approved by the Division, determine whether it is operating
properly. This flare must be equipped with an operational auto -igniter according to the
schedule in Regulation Number 7, Part D, Section II.B.2.d.
15. The 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.
16. 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.
17. 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
18. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Initial Testing Requirements
19. 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. Testing
must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must
be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants
using Division approved methods. Results of site -specific sampling and analysis must be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
21. All previous versions of this permit are cancelled upon issuance of this permit.
22. This permit replaces the following permits and/or points, which are cancelled upon issuance
of this permit.
Existing Permit
Number
Existing
Emission Point
New Emission Point
15WE1413
123/4567/005
123/4567/001
23. 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 (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Page 5 of 10
atzo
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
24. 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
25. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
26. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
27. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
28. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
29. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
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
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
30. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
31. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
April 13, 2016
Issued to Encana Oil a Gas (USA) Inc.
Issuance 2
July 13, 2017
Issued to Crestone Peak Resources Operating, LLC.
Issued as final approval.
Issuance 3
This Issuance
Issued to Crestone Peak Resources Operating, LLC.
Permit modification to group Point 005 and Point
001 into one point (Point 001), and to update
emission factors and throughput.
Page 7 of 10
Ito
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
3,337
167
Toluene
108883
3,137
157
Ethylbenzene
100414
146
7
Xylenes
1330207
899
45
n -Hexane
110543
28,689
1,434
2,2,4-
Trimethylpentane
540841
54
3
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:
Process O1: Condensate tanks throughput
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0194
0.0194
AP 42
CO
0.0883
0.0883
VOC
10.91
0.5455
ProMax
Page 8 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
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
71432
Benzene
0.0349
1.75 * 10-3
108883
Toluene
0.0328
1.64* 103
100414
Ethylbenzene
0.0015
7.65 * 10"5
1330207
Xylene
0.0094
4.70 * 10-4
110543
n -Hexane
0.3000
1.50* 10-2
540841
2'2'4-0.0006
Trimethylpentane
2.83 * 10-5
Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The NOx and CO
emission factors listed in the table above are based on a higher heating values of 2,640 Btu/scf, and a gas -
oil -ratio (GOR) of 108 scf/bbl.
Process 02: Combustion of pilot light gas
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
N0x
68.0
68.0
AP -42 Chapter
13.5
CO
310.0
310.0
Note:
The NOx and CO emission factors listed in the table above were obtained by multip ying the AP -42
Chapter 13.5 emission factors (0.068 lb/MMBtu for NOx and 0.31 lb/MMBtu for CO) by a heat
value of 1,000 Btu/scf. Actual emissions are calculated by multiplying the emission factors in
the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on
a constant rate of 25 scf/hr. Monthly pilot light gas throughput shall be determined by
multiplying this hourly pilot gas throughput by the enclosed combustor monthly hours of
operation. There is one (1) enclosed combustor equipped with a single pilot light used to
control emissions from the condensate storage tanks.
Total actual emissions are obtained from the sum of emissions resulting from the natural gas
routed from the condensate tanks to the enclosed combustor(s) (process 01) and the combustion
of pilot light gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This 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:
Page 9 of 10
COLORADO
Air Pollution Control Division
Department of Pubttc Heatth & Ennronment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
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
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
ktrado A:c Perrojtting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Ben Fischbach
Package if: 427572/034911
Received Date: 5/11/2020
Review Start Date: 7/28/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,SIC Quadrant Section Township Range I
County AIRS ID 123 IItENW 14 25 60
Plant AIRS ID: 5630
Facility Name: Grant Salsbury₹Imquist 14H-C268 Battery
Physical
Address/Location _
County: Weld County
Type of Facility: Exploration&Production Well Pad "s 7€
What industry segment?Oil&Natural Gas Production&Processing ;Jr
Is this facility located in a NAAQS non-attainment area? ,Yes
If yes,for what pollutant? Ozone jN00&VOC),
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Paint# Permit#
(Leave blank unless APCD Eteissions5ourceT E Emissions (Leave blank unless Issuance Self Cert Engineering
Type Equipment Name Action
Control? APCD has already ft Required? Remarks
has already assigned)
assigned)
Permit
001 Storage Tank TANKS Yes 15WE1413 3 Yes Modification
All new
conditions in
I.: this permit will.
f,.. also exist in
15WE1413,so
will not require
Permit self certification
002 Storage Tank PV/ Yes 15W05414 3 No Modification of this permit..
.ded min
service..
Permit Package.
003 Liquid Loading LOAD-1 Yes 15WE1415 3 Yes. Modification 434°11
oe'wit Initial
014 Separator Venting Buffer Yes 20W 20606 1 Yes Issuance
P
Section 03-Description of Project
Applicant proposes the modification of the permits 15WE1413,15WE1414,15WE1415,and the permitting of a.new separator venting point,covered under point
014 on permit 20WE0606
Modification to 15WE1413 includes•New requested throughput limit and new site-specific emission factor based on the addition'of tanks(from the existing point
005)to the..battery..Tanks from point 005 merged due to removal of VRT upstream of those tanks..
Modification to 15 WE1414 includes:Development of new site-specific emission factor and removal of control device.
Modification to 15461415 includes:New requested throughput limit,using 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
Point 014 has uncontrolled PTE 0100 tpy,
Section 05-Ambient Air Impact Analysis Requirement so is requesting a syn minor permit.
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs'and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPS
Prevention of Significant Deterioration(PSD) _
Title V Operating Permits(OP) - J
Non-Attainment New Source Review(NANSR)
Is this stationary source a major source? d'rd2.v„"g...
If yes,indicate programs and which pollutants: SO2 NOx CO VOC_PM2.5 PM10 TSP HAPS
Prevention Operating
of acnPermits
Significant Deterioration(PSD) EI Flop
Title V Operating Permits(OP)
Non-Attainment New Source Review(NANSR)
Storage Tank(s)Emissions Inventory
Section 01-Administrative Information
•
Facility AIRS ID: 123 ,, 9E30 : 001
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit Twenty-six(26)500-bbl Fixed Roof Storage Tanks usedto store Condensate
Description:
Emission Control Device ECD .
Description:
Requested Overall VOC&HAP Control Efficiency%: 95,0
Limited Process Parameter Liquid Throughpufr v >'
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= - 56,164.0 Barrels(bbl)per year
Requested Permit Limit Throughput= 95,630.0 Barrels(bbl)per year Requested Monthly Throughput= Si'-2.0 Barrels(bhl)per month
Potential to Emit(PTE)Condensate Throughput= .. 95,630.0 Barrels(Ski)per year -
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= _ - 2640.0 Btu/scf
Volume of waste gas emitted per BBL of liquids GOR combines flash and W&6 losses
produced= 108.0 scf/bbl
Actual heat content of waste gas routed to combustion device= . MMBTU per year
Requested heat content of waste gas routed to combustion device= ..;3.t MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= +MMBTU per year
Control Device
Pilot Fuel Use Rate:- 25 scfh _:'MMscf/yr
Pilot Fuel Gas Heating Value: •1000 Btu/scf .. :MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions?
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC - 10.9100 0.5455 Site Specific.E.F.(includes flash) Emission factors are based on a combined sales gas and
Benzene 0.0349 1.75E 03 Site Specific E:F.(Includes flash) pressurized liquid sample,which was then run through
Toluene D0328 .64E 03 Site Specific ER.(Includes flash) the entire process.Will require initial sampling of
Ethylbenzene 0.0015 2.61E Site Specihc ER(includes flash) pressurized liquid routed to storage tanks to verify the
Xylene 0.0094 4.z Site Specific E.F::(includes flash) permitted emission factors are not exceeded.
n-Hexane 0.3000 i 54,,: Site Specific E-F:(includes flash)
224TMP 0.0006 L 83E-OS Site Specific B F.(includes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10
PM2.5 _..0 "d'r
SOx 1400
NOx 0.0680 ..;194
CO 0.3100 0,0883 et'
Pilot Light Emissions
Uncontrolled Uncontrolled---
Pollutant (lb/MMBtu) (lb/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 CO
' PMZ.5 ,10000
50x 0 0000
NOx 0.0680 58.0000 AP-42 Chapter 13.5 Industrial Flares(NO2) •
VOC 0..^.000
CO 0.3100 311 3000 AP 42 C`:aeter 13.5 Industrial Flares(CO)
•
2 of 8 K:\PA\2015\15WE1413.CP9
Storage Tank{s)Emissions Inventor,
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) (bs/month)
PM10 0.0 0.0 0.0 3.0
PM2.5 0.0 (k.C1 1 0.0 ;._ 0 0
SOx 0.0 0.0 .. 0.0 _ 0.0
NOx L.`] 05I ...5.. 1.S -_ 158.7
VOC 000.4 15 3 521.7 :1-110.5
CO -..3 2.51 251 4.3 1 3 ?53
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 333,-` €3001 3
Toluene 3136.7 :1:42.2 157
Ethylbenzene 146.3 85.3 1<'.0 1
Xylene 898,9 527.3 _u 3°5 45
n-Hexane 28689.0 1430
224 TMP 54.0 __.. 3
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B
Regulation 7,Part D,Section LC,D,E,F
Regulation 7,Part D,Section 1.G,C
Regulation 7,Part D,Section 11.0,0.1,C.3 -
Regulation 7,Part D,Section II.C.2. Sanane tan,
Regulation 7,Part D,Section II.C4.a.(i) , _.o.-. 1 gob,..r o
Regulation 7,Part D,Section II.C.4.a.(ii) - rc 3o1 sub'.
Regulation 6,Part A,NSPS Subpart Kb Stogago 7.on5 4 at sunl_
Regulation 6,Part A,NIPS Subpart 0000 _-..- . s out suLoect 15
NSPS Subpart 00OOa 3goravo Tani:is not collect to t!555 000'00
Regulation 8,Part E,MACT Subpart HH 3-,3-age.an.,is not<,,,b[act to u<00T boo
(See regulatory applicability worksheet for detailed analysis))
Section 07-Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks,does the company use the state default emissions factors to
estimate emissions?
fives,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to he greaterthan or equal to SU tpy?
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 1.4-03.
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(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 an-line),then it maybe appropriate to use an
older site-specific sample.
If no,the permit will contain en"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company request a control device efficiency pa y que ygreater than 95%for a Flare or combustion device? -" 1
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
3 of 8 K:\PA\2015\15W E1413.CP3
Storage'T nj_ )Fo-snions
Section 08-Technical Analysis Notes
While the tank count of point 001 is increasing with this permitting action,the increase is due to the grouping of points 001 and 005(i.e.,no new tanks are being physically constructed) Therefore,these tanks are not
subject to Regulation 7,Part D,Section II.C.4.a.
Section 09-5CC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process#, SCC C de gx2. � Pollutant Factor Control% Units
Cor 01 hae^ `'� PM10 0 lb/1,000 gallons Condensate throughput
PM25 0 lb/1,000 gallons Condensate throughput
SOx .9 20. lb/1,000 gallons Condensate throughput
NOx 2 lb/1,000 gallons Condensate throughput
VOC ,_ lb/1,000 gallons Condensate throughput
CO 32.12 2 lb/1,000 gallons Condensate throughput
Benzene 0.80 ;, lb/1,000 gallons Condensate throughput
Toluene _.. .., lb/1,000 gallons Condensate throughput
Ethylbersaene 000c 25 lb/1,000 gallons Condensate throughput
Xylene r.2 ... lb/1,000 gallons Condensate throughput.
n-Hexane 7:4 97 lb/1,000 gallons Condensate throughput
224 TMP 0 i _s lb/1,00D gallons Condensate throughput
4 of 8 K:\PA\2015\15WE1413.CP3
•
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions.
Coloiado R elation Ce its A and B-ADEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section I1.0.1.a)? Source Requires an APEN.Got.
•
2. Isthe constructiondate(service d t)prior to 12/30/2002 and not modified after 12/31/2W2(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? Go to next question
3. Aretotalt ility uncontrolled VOC emissions greater than 5TPY,500 g ater than ROTPY or CO emissions greater than 10TPY(Regulation 3,Part B,Section 11.0.317 Source Requires a permit
• NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from the individual source greater than ire?(Regulation 3,Part A,Section lLDd.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 1.12and1.14 and Section 2 for additional guidance on grandfather applicability)? No Go to next question
3. Are total facility uncontrolled VOC emissions greater than 2TPY,NO4 greater than 5TPY or CO emissions greater than 1OTPY(Regulation 3,Part B,Section 11.0.2)7 Yes Source Requires permit
..a eermr,
Colorado Regulation T,Part 0,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 l.A.1)7 Continue-You have Indicated th
2. Is this storage tank located at oil and gas operations that coiled,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of natural gas processing plant(Regulation 7,Part D,Section l.A.1)? r.- Continue-You have indicated th
3. Is this store.tank located at a natural gas processing plant(Regulation 7,Part D.Section l.0)? sie Storage Tank 6 not subject to Re ,
4. Does this storage tank contain condensate?
5. Does this storagetank exhibit"Flash"(e.g.staring non-stabilized liquids)emissions(Regulation 7,part O,Seetlon 1.0.2)?
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.0.3.a(IIII? Yes.
Part 0,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part 0,Section I.C.2—Emission Estimation Procedures
Part D,Section 1.0—Emissions Control Requirements
Part D,Section LE—Monitoring
Part D,Section I.F—Recnrdkeeping and Reporting
r tza T
Part D,Section 1.0.2-Emissions Control Requirements
Part D,Section 1.01.5 and h—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? 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 stationaor natural gas processing plane(Regulation 7,Part 0,Section 11.07 •- Go tothe nest question-You ha
3. Dog this storage tank have a fixed roof(flegulenion 7,Part0,Section ll.A.20)7 Yes -.Goto the next question
4. Are ntrolled actual emissions of this storagetank equalt or greater than 2tons per year VOC(Regulation 7,Part D,Section ll.C.1.c(? Yes Source is subject to parts of Reg,
Part D,Section 11.8—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section II.C1-Emissions Control and Monitoring Provisions
Pert 0Section 1103 Recordkeepieg Requirements
5 Does the orag tank contain only t hl d(grid(Regulation 7,Part D,Sectionil.C.2.b)? (No • :(Source is subject to all provision,
Part D,Section II.C2-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 ll.C4.a.(i)? No J Storage Tank 6 not subject to Re
Is the controlled storage tank located at a well production facility, al gas compressor station,or natural gas processing plant constructed on or after January 1,2021 or located at a facility that wa modified on or after-January 1,
7 2024 such that an additional controlled storage vessel is constructedl receive anticipated ncreasen throughput of hydrocarbon liquids or produced water(Regulation 7,Part 0,Section II.C.4.a.I(I
40CFR.Part60 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 met'ers(m)1"472 BB1s1(40 CFR 60,110b(a))? N `4 Storage Tanks not subject NSPS
2 Does the storagevessel meet the following exemptonn 60111b(d)(4)7
a.Does theveesel has design capacity less than or equal to 1,589.874 m'I-10,000 BBL)used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined In youth?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40CFR60.110b(a))?
4. Does the tank meet the definition of"storage vessel"'in 60.11167
5. Does the storage vessel store a"volatile organic liquid(VOL)"aas defined In 60.1115?
6. Does the storage vessel meet any one of the following additional exemptions:
a.la the storage vessel a pressure vessel designed to operate In excess of 204.9 Var.,psi)and without em'sions to the atmosphere 160.11ob(d)(2))7;or
b.The design capacity is greater than or equal to 151 me P-950 BBL]and stores a liquid with a maximum truevapor pressure°less than 35 kPa(60.1106161)?;or
c.The design capacity is greater then 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 fallowing exemptions from control requirements: ..,-._.
a.The deggn capacity Is greater than or equal to 151 me[^950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but lessthan 5.2 kPa7 or
b.The deggn capacity Is greater than or equal to75 NI'(-472 BBL]but less than 151 in°P-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 kPa7 •
lcrr gedunk!,notmildestto PnSlb I
40CFR,Part 60.Subpart 0000/0000a,Standards of Performance far 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? Continue-You have indicated th
2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)between August 23,2011 and September sA,2015? No Storage Tank is not subject NSPS
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)after September 18,2015? Yes Go tothe next question
4. Are potential VOC emissions'from thelndlvidualstorage vessel greeter than or equal to Stens per year? No Storage Tank is not subject NSPS
Does this storage vessel meet the definition of'storage vessel"'per 60.5430/60.5430a7
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 llg?
(Note:If a stoagevessel is previously determined to be subject se NIPS 0000/0000a dueto emissions above 6 tons per year VOC on the applicability determination date,itshould remain subject to NSPS 0000/0000a per
60.536S(e)(2)/60.5365a(e)(a(even if potential VOC emissions drop below 6 tons per year]
40CFR,Part63,Subpart MAR NH,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: I :. (Continue-You have indicated th
a.A facility that processes,upgrades or stores hydrocarbon liquids'(64.760(x)(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)I?
2. Is the tank located at a facility that is major'for HAPs? No Storage Tank is not subject MAC
3. Does the tank meet the definition of"garage vessel""in 63.7617
4. Does the tank meet the definition of"storage vessel with thepetential for flash emissions"'per 63.761?
5. Is the tenksubject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 00007
SubpartA,General provisions per 463.764(a)Table 2
563.766-Emissions Control Standards
563.773-Monitoring •
§63.714-Remrdkeeping
§63.715-Reporting
RACT Review
RACE review is regalred If Regulation]does not apply AND lithe tank Is In the non-attainment area.If the tank meets both criteria,then review RACT requirements.
Disclaimer \
This dccument assists operators woh determining applicability of certain requirements of the Clean Air Act.its implementing regulations,end Air Quality Control Commission regulations.This document is not
a rule arregulation,and the analysis it contains may not apply to a particular situation based upon the individual facts end circumstances.This document does not change or substitute for any law,regulation,
r 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 implenenh'ng 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"end"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,Inc.
County AIRS ID 123 History File Edit Date 913012020
Plant AIRS ID 9E30 Ozone Status Non-Attainment
Facility Name Grant Salisbury Elmquist 14H-C268
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 I-APs VOC HAPs
ID
Previous FACILITY TOTAL 0.2 0.2 0.0 0.0 17.7 1,712.3 2.2 32.5 81.6 0.2 0.2 0.0 0.0 4.2 86.7 2.2 14.3 4.4
Previous Permitted Facilit r total 0.2 0,2 _ 0.0 0.0 10.4 1,711.9 2.2 24.2 81.5 0.2 0.2 0.0 0.0 3.3 86.3 2.2 _12.5 4.3
001 15WE1413 26-Condensate Tanks(receives liquids from 0.0 0.0 0.9 522.0 4.3 18.1 0.0 0.0 0.9 26.1 4.3 0.9 Modification-merging with point 001,updating EF
002 15WE1414 7-Produced water storage tanks 1.2 0.4 1.2 0.4 Modification to reduce throughput
003 15WE1415 Condensate Loadout 0.0 11.3 0.1 0.2 0.0 0.6 0.1 0.0 Modification to reduce throughput
•
004 15WE1416 Fugitive Component Leaks 2.2 0.3 2.2 0.3
005 15WE1413'CN 8-Condensate Tanks(w/o benefit of VRT) 0.0 0.0 Cancellation received 5/18/2020-Pointno longer exists
(merged with point 001 upon issuance of 15WE1413)
006 16WE0861.CN COMP-1 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
007 16WE0862:CN-COMP-2 _ 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
008 10W01072,CN- - 0.0 - 0.0 Cancellation received 5/29/2019-.Point no longer exists..
009. 18WE0514.CN 0.0 0.0 Cancellation received 5/29/2019—Pointnolooser exists.
010 18WE0514.CN 0.0 - 0.0 Cancellation received 5/29/2019-Point no longer exists.
011 GP02.CN''. PSI-1 0,0 _ 0.0 Cancellation received.5/29/2019-Point no longer exists.
012 18WE1122.XP COMP-4 7.3 0.40 8.3 0.1 0.9 0.4 1.8 0.1
013 GP02 GM-1(GM Vonec 5.7L.92hp,sn:15807167) 0.100 0.100 8.0 0.6 13.5 0.1 0.100 0.100 0.9 0.6 1.8 0.0
014 20WE0606 LP Gas Vented from HLP Separators 0.40 162.20 1.80 5.5 0.40 8.10 1.80 0.0 New point
FACILITY TOTAL 0.1 0.1 0.0 0.0 16,6 697.7 2.2 28.0 24.7 0.1 0.1 0.0 0.0 3.1 37.0 2.2 9.8 1.7 VOC: Syn Minor(NANSR and OP)
NOx:Minor(NANSR and OP)
CO: Minor(PSD and OP)
HAPS: Syn Minor n-hexane
HH: Syn Minor
7777:Area
Permitted Facility Total 0.1 0.1 0.0 0.0 8.5 372.9 2.2 16.1 24.6 0.1- 0.1 0.0 0.0 2.2 36.6 2.2 8.0 1.6 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.1 -0.1 0.0 0.0 -1.1 -49.7 0.0 -4.5 Pubcom&modeling not required based on change of
emissions from construction permit sources. •
Total VOC Facility Emissions(point and fugitive) 39.2 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -49.7 Project emissions less than 25/50 tpy
Note 1
Note 2
•
•
Page 6of8 - • Printed 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 3337 3137 14(6 899 28689 54 18.1
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 39 344 0.2
004 15WE1416 Fugitive Component Leaks 39 42 22 230 225 0.3
005 15WE1413.CN 8-Condensate Tanks(w/o benefit of VRT) 0.0
006 16WE0861,,CN COMP-1 0.0
007 16WE0862.CN _COMP-2 0.0
008 16WE1O72.CN 0.0
009 18WE0514.CN 0.0
010 18WE0514.CN 0.0
011 GP02CN PSI-1 0.0
012 18WE1122.XP COMP-4 89 12 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,sn: 158D7167) 149 20 19 11 4 122 0.1
014 20WE0606 LP Gas Vented from HLP Separators 1001 1002 48 343 8671 5 5.5
TOTAL(tpy) 0.0 0.0 0.0 1.8 1.7 0.1 0.6 14.7 0.0 0.0 0.0 0.0 19.0
"Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de rninimns
7 15WE1413.CP3 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmguist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 167 157 7 45 1434 3 0.9
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 2 17 57 0.0
004 15WE1416 Fugitive Component Leaks 39 42 22 230 ,225 0.3
005 15WE1413.ON. 8 Condensate Tanks(w/o benefit of VRT) 0,0
006 16WE0861.CN COMP-1 0.0
007 16WE0862.CN COMP-2 0.0
008 16WE1072CN 0.0
009 18WE0514.CN 0.0
010 18WE0514.CN 0.0
011 GP02.CN PSI-1 0:0
012 18WE1122.XP COMP-4 89 12 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,sn: 158D7167) 149 20 10 11 4 1 22
014 20WE0606 LP Gas Vented from HLP Separators 50 50 2 17 434 'I
TOTAL(tpy) 0.0 0.0 0.0 0.2 0.2 0.0 0.2 1.0 0.0 0.0 0.0 0.0 1.7
8 15WE1413.CP3 9/30/2020
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 15WE1414 Issuance: 3
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Grant Salisbury Elmquist 14H -C268 Battery
Plant AIRS ID: 123/9E30
Physical Location: NENW SEC 14 T2N R68W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
.
Point
Equipment Description
Emissions Control
-
Description
PW
002
Seven (7) 250 barrel fixed roof storage
vessels used to store produced water
None
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:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
PW
002
---
---
1.2
---
Point
Page 1 of 7
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
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.
PROCESS LIMITATIONS AND RECORDS
4. 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
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
PW
002
Produced Water throughput
35,770 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
5. 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)
6. 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.
Page 2 of 7
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
7. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
8. 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
9. This source is not required to follow a Division -approved operating and maintenance plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
10. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
11. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
12. All previous versions of this permit are cancelled upon issuance of this permit.
13. 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,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 3 of 7
COLORADO
Air Pollution Control Division
Department of Publcc Health 6 Environment
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.
14. 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
15. 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. B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
16. 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.
17. 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.
18. 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.
19. 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
Page 4 of 7
cv.,.
p,,,0*0
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
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.
20. 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.
21. 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
April 13, 2016
Issued to Encana Oil Et Gas (USA) Inc.
Issuance 2
July 13, 2017
Issued to Crestone Peak Resources Operating, LLC.
Issued as final approval.
Issuance 3
This Issuance
Issued to Crestone Peak Resources Operating, LLC.
Permit modification to establish site -specific
emission factors.
Issued as Final Approval.
Page 5 of 7
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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
Point
Pollutant
CAS #
Uncontrolled Emissions
(lb/yr)
002
Benzene
71432
270
Toluene
108883
203
Ethylbenzene
100414
6
Xylenes
1330207
38
n -Hexane
110543
229
2,2,4-Trimethylpentane
540841
0
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:
CAS #
Pollutant
Uncontrolled Emission
Factors
lb/bbl
Source
VOC
0.0695
Flash Liberation
Analysis + TANKS
4.0.9d
71432
Benzene
7.55 * 10-3
108883
Toluene
5.67 * 10-3
100414
Ethylbenzene
1.76 * 10-4
1330207
Xylene
1.08 * 10-3
110543
n -Hexane
6.39 * 10"3
Page 6 of 7
ate,
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled Emission
Factors
lb/bbl
Source
540841
2,2,4-Trimethylpentane
0.0
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
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane
PSD
Synthetic Minor Source of: VOC
NANSR
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.ecir.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 7 of 7
Colorado Air Permitting Pr j c
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Ben Fischbach
Package#: 427572/434911;
Received Date: 6/11/2020
Review Start Date: 7/28/2020
Section 01-Facility Information
Company Name: Crestone Peak&Resources Operating,LLC Quadrant Section Township I Range
• County AIRS ID: 123
Plant AIRS ID: 9E30 -.
Facility Name: Grant Salisbury Elmquist 140-C268 Battery
' Physical
Address/Location:
County: Weld County - ,
Type of Facility: Exploration&Production Welt 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 Paint# Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APED Emissions Source Type Equipment Name Control? APCD has already # Required? Action
quire Remarks •has already assigned) assigned)
Permit
001 Storage Tank TANKS Yes 15WE1413 3 Yes Modi
fication
All new
conditions:n
this permit will
also exist in
15WE1413,so
will not require
Permit self certification
002 Storage Tank WV Yes . 15WE1414 3 No Modification of this porrnt
Added mio-
service.
Permit Package
003 Liquid Loading LOAD-1 Yes 15WE1415 3 Yes Modification 434311
Permit Initial
014 Separator Venting Buffer Yes 20WE0606 1 Yes Issuance
Section 03-Description of Project
Applicant proposes the modification of the peimfts 15WE1413,1S W E1414,15WE1415,and the permitting of a new separator venting point,covered under point
014 on permit 20WE0606.
Modification to 15WE1413 includes:New requested throughput limit,and new site-specific emission factor based on the addition of tanks(from the existing point,
005)to the battery.Tanks from point 005 merged due to removal of VRT upstream of those tanks
Modification to 15WE1414 includes Development of new site-specific emission factor and removal of control device. `'�zy,',y �'
Modification to 15WE1415 includes:New requested throughput limit,using State default emission factors.
Sections 04,05&06 Far Division Use Only
Section 04-Public Comment Requirements Is Public Comment Required? Yes
If yes,Why? Requesting Synthetic Minor Permit
Point 014 has uncontrolled PTE>100 tpy,
Section 05-Ambient Air Impact Analysis Requirement so is requesting a syn minor permit.
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? `3ta,
Isthisstationarysourceasyntheticminor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM TSP
TSP HAPs
Prevention of Significant Deterioration(PSD) .ft�t
Title V Operating Perm E ®its(OP) )� lty.l! 4E m
Non-Attainment New Source Review(NAN5R) l
Is this stationary source a major source? No,
If yes,indicate programs and which pollutants: SO2 NOx n CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration IPSO) L ® L
Title V Operating Permits(OP) 11f
Non-Attainment New Source Review(NANSR)
Storage `3n(C(4I EYris510n5 inventory
Section 01-Administrative Information
Facility AIRs 10: 123 ' - 9E312 00X'„`.;:
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit Seven(7)250-bbl Fixed Roof Storage Tanks used to store Produced Water •
Description:
Emission Control Device Not*
Description .. -
Requested Overall VOC&HAP Control Efficiency%: 0.0
Limited Process Parameter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= ' 29,796.0-Barrels(bbl)per year
(Requested Permit Limit Throughput= :323;35,770.0 Barrels(bbl)per year Requested Monthly Throughput= 3C3s'.3 Barrels(bbl)per month
Potential to Emit(PTE)Condensate Throughput= 35,770.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= Btu/scf
Volume of waste gas emitted per BBL of liquids -
produced= scf/bbl
Actual heat content of waste gas routed to combustion device= = MMBTU per year
Requested heat content of waste gas routed to combustion device= .:,MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= - MMBTU per year - -
Control Device
Pilot Fuel Use Rate: scfh ti MMscf/yr
Pilot Fuel Gas Heating Value: Btu/scf 2 i'MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions? rtfir;_�:
Produced Water Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Produced Water (Produced Water "
Throughput) Throu h Throughput)
g P trA- ! 224-TMP 0 .gin,,,; t r^
fffflianatminemesimmOiSieatireafi-fiAtliiAklieBenzene 0430671.3 a.a E.B.73g8�
MINIIMMEMEMMIIIIIIMEMMOIN Toluene •OG05084 7.110360'28`
Ethylbenzene (300 54. 13 `- ,�,3,3
6.39E-03 - Xylenes r€0 c.. 200 213411. iy•
- nHexane =3,23.3.3 0,00071,4". KQ'.
Uncontrolled Uncontrolled ;,.
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source VOC 0.05£794 17011177203q.
(waste heat (Produced Water
combusted) Throughput)
0.0680 f.:.
IMINEM0.3100
Plot Light Emissions
Uncontrolled Uncontrolled
Pollutant (16/MMB₹u) (Ib/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
2 of 8 K:\PA\2015\15WE1414.CP3
Storage Tank(s) Emissions Inventory
Section 05 Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
fibs/month)
PM10
PM25
500
000
VOC
Co
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
09
00
00
00
00
00
00
12
1 035
1 035
1 2
' 2
2111
00
00
00
00
00
00
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
)lbs/year)
Actual Emissions
Uncontrolled Controlled
(ibs/yean) llbs/year)
Requested Permit Limits
Uncontrolled Controlled
fibs/year) lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
270 2
2251
2251
270
270
202 7
1c8 8
168 8
203
203
6 3
5 2
5 2
6
6
38 5
321
32 1
38
38
220 -
190 a
190 5
229
229
00
&'O
00
0
0
Section 06 Regulatory Summary Analysts
Regulation 3 Parts A B
source equires a permit
Regulation 7 Part D Section ICDE F
Stora+e link is not sub ot- to Rerulatian 7 Part 0 Section I C F
Regulation 7 Part D Section I G C
.,tonce Tank Is not subie't to Rksulanon 7 section I 0
Regulation 7 Part D Section II B C 1, C 3
Storm '.,nk is not sublets to R gulanon 7 Part D Sec' on II
Regulation 7 Part D Section II C 2
5tomee Tank is not suolnc to Reeule um 7 Part 0 Sect on H C 2
Regulation 7 Part D Section II C 4 a(I)
Storage Tank is not suoler,. to Re ulatiun 7 Part D 5-cto- II C 4 alil
Regulation 7 Part ()Section II C 4 a (d)
Stone_ Tark is not sub ec to Re ulatior 7 Part 0 Sectio^ it C 4 alnl
b I
Regulation 6 Part A NIPS SubpartKb
Storage Tank rs not nab ea to ASPS Kb
I
Regulation 6 PartA NSPSSubpart0000
Storage ail iiu net subiect to SOPS 0000
NSPS Subpart 00003
Storage Tank is not ubiea to NSPS OCCOa
Regulation B Part E MALT Subpart HH
Produced Water Storage ank is not nab ect to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 Initial and Penodic Sampling and Testing Requirements
Far condensate or crude oil tanks does the company use the state default emissions factors to
estimate emissions) PNot Appllcehid
If yes are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes the permit will contain an Initial Compliance testing requirement to develop a site specific emissions factor based an guidelines in PS Memo 14-03
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 (for produced water tanks a pressunze liquid sample must be analyzed using flash liberation analysis), This sample
should be considered representative which generally means site -specific and collected within one year of the application received
date However if the facility has not been modified (e g no new wells brought on line) then it may be appropriate to use an
older site -specific sample On's-'L,
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
I/
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 _
See Tab 002FIashUberationCalculation for fiash liberation analysis calculation page which was used to venfyalculated emission factors rJ
tti
Section 09 SCC Coding and Emissions Factors (For inventory Use Only)
AIRS Point
Process H
SCC Code
Uncontrolled
Emit s
Pollutant FactorControl Y Unite
032 01 '4dQ93-15 Fixed Root Tank ProdutCdWater,workin„ Dreathinrtla itig lossesy,, ,z,� ��rz y4 PM10 000 0 lb/1 000 gallons Produced Water throughput
PM2 5 000 0 l6/1000 gallons Produced Water throughput
500 PREF, 0 lb/1 000 gallons Produced Water throughput
NOx 000 0 lb/1 000 gallons Produced Water throughput
VOC 165 0 lb/1 000 gallons Produced Water throughput
CO 0 00 0 lb/1 000 gallons Produced Water throughput
Benzene 0 18 0 lb/1 000 gallons Produced Water throughput
Toluene 0 13 0 lb/1 000 gallons Produced Water throughput
Ethylbenzene 0 CO 0 lb/1 000 gallons Produced Water throughput
Kylene 0 03 0 lb/1 000 gallons Produced Water throughput
n Hexane 015 0, lb/1 000 gallons Produced Water throughput
224 TMP 0 00 0 lb/1 000 gallons Produced Water throughput
\ 3 of 8 K \PA\2015\1SWE1414 CP3
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex = Q ' MW • Xx / C
Ex = emissions of pollutant x
Q = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
MW 35.8485 I b/I b-mo l
Throughput 365 bbl/year
Gas-to-Oil Ratio (GOR) 1.8 scf/bbl
mass fraction (°%o) Emission Factor (lb/bbl) Emissions (lbs/year) 109500 bbl/yr
Helium
CO2 31.47 0.07664027 lb/bbl W&B emissions
N2 4.40
H2S 8392.11 lb/yr w&b
methane 13.48 _
ethane 14.35
propane 12.56
isobutane 1.67
n-butane 4.63 FLASH W+B Total
isopentane 0.84
n-pentane 1.03 224-TMP 0.000000 224TMP 0.000000
cyclopentane 0.38 Benzene 0.006711 Benzene 6.71E-03
n-Hexane 3.34 Toluene 0.005034 Toluene 5.03E-03
cyclohexane 0.51 Ethylbenzene 0.000156 Ethylbenzen 1.56E-04
Other hexanes 2.77 Xylenes 0.000956 Xylenes 9.56E-04
heptanes 0.18 n•Hexane 0.0056801 n-Hexane 5.68E-03
methylcyclohexane 0.21
224-TMP 0.00
Benzene 3.95 VOC 0.06173 7.76E-03 VOC 0.06949
Toluene 2.96
Ethylbenzene 0.09
Xylenes 0.56
C8 0.34
C9 0.08
C10 0.20
C11+ ��j��
Weil it; "tsrif%�f� � ep Jff`�f'i i�: f„sssi� f'.'s"
Total i3ili�i i..i:elinz d �.r i Af iii � s is f;; d
VOC Wt % my
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3Par.A andB APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissionsfrom any criteriapollutants f this individual source greater than 2 TPY(Regulation t Part A,Section llol.a)? Source Requires an APEN.Go to
2. Produced Water Tanks have no grandfathering provisions Go to next question
3 Aretotal facility uncontrolled VOC emissions greater h STPY NOx greater than 10 TM'or CO emissions greater than lD TPY(Regulation 3,Part B,Section 11.03)7 Source Requires a permit
Ire. cirErm ir ikr. ,-,nc.tCrick
NON-ATTAINMENT
1. Are uncontrolled emissions from any cnteia pollutants from this individual source greater than l TPS(Regulation 3,Part A,Section 11.0.1.x)7 :WiVa1if Source Requires an APES.Go to
2. Produced WaterTanks have no grandfathering provisions Go to neat question
3. Aretotal facility uncontrolled VOC emissions greater than 2TPY,Noe greater than 5 TPY or CO emissions greater than SOTPY(Regulation 3,Part B,Section 11.0.2)? yv¢`w Source Requires a permit
JS
Colorado Reeulation T Part D.Section I.C-F&G
1. ls this storage tank located in the a-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section 1..11? 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 1A.1)? 3. Continue-You have indicated th
3. Isthis storage tank located at a natural gas processing plant(Regulation 7,Part D,Section I.G)? As Storage Tank is not subject to Re
4. Does this storage Pink contain condensate? No
5. Does this storage rank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,part D,Section l.G.2)? -
6. Are uncontrolled.actual emissions of this storage tank equal to or greater than 2 tons per year AOC(Regulation 7,Part D,Section 1.0.1.a(1i()? 4p ≤
Part D,Section I.Cut—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part O,Section I.C2—Emission Estimation Procedures
Part D,Section I.D—Emissions Control Requirements
Pert 0,Section LE—Monitoring
Part D,Section I.F—Recordkeeping and Reporting
Sr-
Part D,Section 1.G:2-Emissions Control Requirements
Part O,Section I.C.l.a and b—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Colorado Regulation T,Part D.Section II
1. Is this storagetank located at atansmission/storage facility? iiro 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 0,Section ll.C)? Go to the mot question-You ha
3. Does this storage tank have a fixed roof(Regulation 7,Part D Section ll.A.2017 ls Goto the neetquestion
4 Are uncontrolledact 1 emissions of this storagetank erfir Ato or greater than 2 tons per year VOCIRegnlaton 7,Part 0,Section ll.C.1.c1? 'Pto K Storage Tank is not subjectto Re
Part D,Section II.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section II.G1-Emissions Control and Monitoring Provislons
Part D,Section II.C3-Recordkeeping Requirements {{
5. Does the storset k ti my"stabilised"Iqud(Rgut 7,P D Section ll.C.2.b(? p ..../I5torage Tank is notsubjeito Ra
Part 0,S tion IIG2 C,pture andM g tg for Storage ks fitted with Alr Pollution Control Equipment
Is the lled storage tank l d at a wellp d facility, t l gas compressor-Nation,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
G. that an additional t I I d storage vessel is constructed to receive an anticipated increase inthroughput ofhydrocarhon liquids or produced water(Regulation 7,Part O,Section l IC9a I)7 No .Storage Tank is not subjectto Ra
Is the controlled stn age tank located at a well production facility,natural gas compressor Nation,or natural gas processing plant constructed on or afterlanuary 1,2021 or located at a facility that was modified on or afterlanuary 1,
7 2021 such that an addition1 controlled storagevessel is constructed to receive an anticipated increase n throughput of hydrocarbon lquids or produced water(Regulation 7,Part 0,Se Ron II.C4.z.(ii)?
40 CFR.Part 60,Subpart Kb,Standards of Performance far Volatile Organic Liquid Storage Vessels
1. Is the individualstorage vessel capacity greater than or equal to 75 cubic meters lm°([-472BBLs](40 CFR 60.110b(a))? INo :Storage Tanks not subject NSPS
2 Duoe the storage vessel meet the following exemption in 60111b(d)(4)?
a.Does the vessel has a design capacity less than or equal to 1,589.874 m'(-10,W0 BBL]used for petroleum'o condensate stored,processed,or treated prior to custody transfer'as defined in 60.111b?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)after July 23,1984(40 CFRr60.110b(a))?
4. Does the tank menthe definition of"storage vessel"'In 60.1116? -
5. Does the storage vessel store a"volatile organic liquid(VOL)"sas defined in 60.1116?
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 2049 bra(-23.7 psi]and without emissions to the atmosphere l60.110h(d)(2))7;o
b.The design capacity is greater than or equal to 151 m'[`950 BBL]and stores a liquid with a maximum true vapor pressure'lessthan 3.5 kPa(60.110h(b))?;or
c The design capacity is greaterthan or equal to 75 Mu(-472 BBL]but less than 151 m°1-9S0 Bet]and stores a liquid with a maximum true vapor pressure'lessihan 15.0 kPa(60.11ob(b))?
7. Ones the storage tank meet either one of the following exemptions from control requirements:
a.The design capacity is greater than or equal to 161 nil'['95o BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2kPa?;or
h.The d ig p ty is g t than ual to 75 M5[`472 BBL]but less than 151 msI-9506BE]and stores a liquid with a maximum true vapor pressuregreater than or equal to 15.0 kPa but less than 276 kPa?
16:e .kLimt tiSP,.. �.
40 CFR,Part 60,Subpart0000/00008,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 naturalgas transmission and storage segment of the industry? v. Continue-You have Indicated th
2. Was the storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)between August23,2011 and September 18,2015? e/dd`M1ii()Storage Tank is not subject NSPS
3. Was this storage v sal constructed,reconstructed or modified(see definitions 40 CFR,60.2)after September 18,2015? 3e 4~-i Go to the next question
4 Are potential VOC from the individual storage vessel greater than or equal to 6tons paryean? Ord Y'.».Storage Tank is not subject NSPS
S Doesths storage vessel meet the definition of storage vessel.'per 60.5430/60.5430x7
6 Is the smragevessel subject to and controlled in accordancewth requirements for storage vessels in.CFR Part GO Subpart Kb or 40 CFR Part 63 Subpart HR? r?,
[Nate:If a staragevessel is previously determined to be subjectto NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to RISES 0000/00000 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,OII and Gas Production Facilities
1. IstheOtorage tanklocated at an oil and natural gas production facility that meets either of the following Criteria EYE 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 stares natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered toe final end user'(63.760(a)(3))?
2. Is the tank loatedat a facility that Is majors for HAPs? .
3 Does the tank meetthedefnyion of"storage vesse in 63.761?
4. Does the tank meet the definition-of storage vessel with the potential for Flash emissions"'per 63.7617 n' '.
5. Is the tank subjectto control requirements under 40 CFR Part 60,Subpart Kh or Subpart 0000?
Subpart A,General provisions per 463.064(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
§63.775-Reporting
RACT Review
PACT review Is required if Regulation 7 does not apply AND If the tank is inthe non-attainment area.If thetank meets both criteria,then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act as implementing regulations,and Air Quality Control Commission regulations.This document is not
a rule sr 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 eraahstilute for any law,regulation,
oranymtherlegally 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,
end 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 interpretelions and recommendations.Mandatory terminology such as'must"and"required"are intended to descdhe controlling requirements under the terms of the Clean Air Act and Air
Qualify Control Commission regulations,but this document does not establish legally binding requirements in end of itself.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Crestone Peak Resources Operating.Inc.
County AIRS ID 123 History File Edit Date 913012020
Plant AIRS ID 9E30 Ozone Status Non-Attainment
Facility Name Grant Salisbury Elmquist 14H-C268
EMISSIONS-Uncontrolled(tons per year). EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H26 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 0.2 0.2 0.0 0.0 17.7 1,712.3 2.2 32.5 81.6 0.2 0.2 0.0 0.0 4.2 86.7 2.2 14.3 4.4
Previous Permitted Facilit/total 0.2 0.2 0.0 0.0 10.4 1,711,9 2.2 24.2 81.5 0.2 0.2 0.0 0.0 3.3 86.3 2.2 12.5 4.3
001 15WE1413 26-Condensate Tanks(receives liquids from 0.0 0.0 0.9 522.0 4.3 18.1 0.0 0.0 0.9 26.1 4.3 0.9 Modification-merging with point 001,updating EF
002 15WE1414 7-Produced water storage tanks 1.2 0.4 1.2 0.4 Modification to reduce throughput
003 15WE1415 Condensate Loadout 0.0 11.3 0.1 0.2 0.0 0.6 0.1 0.0 Modification to reduce throughput
004 15WE1416 Fugitive Component Leaks 2.2 0.3 2.2 0.3
005 15WE1413.ON 8-Condensate Tanks(w/o benefit of VRT) 0`.0 0:0 Cancellation renewed 5/18/2020 Point no longer exists
• (merged with point 001 upon issuance of 15WE1413)
006 16WE0861.CN COMP-1 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
007 16WE0862.CN COMP-2 0.0 0.0 Cancellation received 5/29/2019-.Point:no longer exists.
008 16WE1072.CN _ 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
009 18WE0514.CN 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
010 16WE0514.CN 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
011 GP02.CN PSI-1 0.0. _ 0.0 Cancellation received 5/29/2019-Points no longer exists.
012 18WE1122.XP COMP-4 7.3 0.40 8.3 0.1 0.9 0.4 1.8 0.1
013 GP02 GM-1(GM Vortex 5.7L,92hp,sn:15807167) 0.100 0.100 8.0 0.6 13.5 0.1 0.100 D.100 0.9 0.6 1.8 0.0
014 20WE0606 LP Gas Vented from HLP Separators 0.40 162.20 1.80 5.5 0.40 8.10 1.80 0.0 New point
FACILITY TOTAL 0.1 0.1 0.0 0.0 16.6 697.7 2.2 28.0 24.7 0.1 0.1 0.0 0.0 3.1 37.0 2.2 9.8 1.7 VOC: Syn Minor(NANSR and OP)
NOx:Minor(NANSR and OP)
CO: Minor(PSD and OP)
HAPS: Syn Minor n-hexane
HH: Syn Minor
7777:Area
Permitted Facility Total 0.1 0.1 0.0 0.0 8.5 372.9 2.2 16.1 24.6 0.1 0.1 0.0 0.0 2.2 36.6 2.2 8.0 1.6 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.1 -0.1 0.0 0.0 -1.1 -49.7 0.0 -4.5 Pubcom&modeling not required based on change of
emissions from construction permit sources.
Total VOC Facility Emissions(point and fugitive) 39.2 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -49.7 Project emissions less than 25/50 tpy
Note 1
Note 2
•
Page 6 of 8 - Printed 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 3337 3137 146 899 28689 54 18.1
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 39 344 0.2
004 15WE1416 Fugitive Component Leaks 39 42 22 230 225 0.3
005 15WE1413 CN 8-Condensate Tanks(w/o benefit of VRT). 0.0
006 16WE0861.CN COMP-1 0.0
007 16WE0862.CN .COMP-2 0,0
008 16WE1072.CN 0.0
009 18WE0514.CN. ^, .. .... 0.0
010 .18WE0514.CN 0.0
011 GP02;CN PSI-1 , 0.0
012 18WE1122.XP COMP-4 89 1'2 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,sn: 158D7167) 149 20 19 11 4 122 0.1
014 20WE0606 LP Gas Vented from HLP Separators 1001 1002 48 343 8671 5 5.5
TOTAL(tpy) 0.0 0.0 0.0 1.8 1.7 0.1 0.6 14.7 0.0 0.0 0.0 0.0 19.0
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red...ext: uncontrolled emissions w7,de minirnus
7 15WE1414.CP3 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 167 157 7 45 1434 3 0.9
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 2 17 57 0.0
004 15WE1416 Fugitive Component Leaks 39 42 22 230 22.25 0.3
005 15WE1413.CN 8-Condensate Tanks(wlo benefit of VRT) 0.0
006 16WE0861.CN COMP-1 0:0
007 16WE0862,CN . COMP-2 .: 0.4
008 16WE1072.CN 0.0
009 18WE0514,CN 0.0
010 18WE0514.CN 0.0
011 GP02.CN PSI-1 0.0
012 18WE1122.XP COMP-4 89 12 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,sn: 158D7167) 14920 19 11 4 1 22
014 20WE0606 LP Gas Vented from HLP Separators 50 50 2 17 434 1
TOTAL(tpy) 0.0 0.0 0.0 0.2 0.2 0.0 0.2 1.0 0.0 0.0 0.0 0.0 1.7
8 15WE1414.CP3 9/30/2020
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: 15WE 1415 Issuance: 3
Date issued:
Issued to:
Crestone Peak Resources Operating, LLC
Facility Name: Grant Salisbury Elmquist 14H -C268 Battery
Plant AIRS ID: 123/9E30
Physical Location: NENW SEC 14 T2N R68W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Condensate
Loadout
003
Truck toadout of condensate by
submerged fill
Enclosed Flare
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
Page 1 of 11
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
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
3. 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
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
Condensate
Loadout
003
=
---
0.6
---
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.
5. 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.
6. 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
Page 2 of 11
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
Condensate
Loadout
003
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. 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
Process Parameter
Annual Limit
Condensate
Loadout
003
01
Condensate Loaded
95,630 barrels
02
Combustion of pilot light gas
0.22 MMSCF
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
8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution
control equipment. Compliance with Section II.C.5. must be achieved in accordance with the
following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
Page 3 of 11
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
• 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.
11. Storage tanks must operate without venting at all times during loadout. (Regulation Number
7, Part D, Section II.C.5.a.(ii))
12. 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.
13. 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.
• 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.
Page 4 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
14. 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.
15. 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.C5.a.(vi))
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 (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your OM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
Page 5 of 11
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
ADDITIONAL REQUIREMENTS
20. All previous versions of this permit are cancelled upon issuance of this permit.
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section I I.C. )
• Annually by April 3e whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in
ozone nonattainment areas emitting less than 100 tons of VOC or 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.
22. The requirements of Colorado Regulation Number 3, Part D shall 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
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
Page 6 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
24. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operators agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Page 7 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & cn+nronrnent
Dedicated to protecting and improving the health and environment of the people of Colorado
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
April 13, 2016
Issued to Encana Oil a Gas (USA) Inc.
Issuance 2
July 13, 2017
Issued to Crestone Peak Resources Operating,
LLC.
Issued as final approval.
Issuance 3
This Issuance
Issued to Crestone Peak Resources Operating,
LLC.
Modification to reduce throughput and
emissions.
Page 8 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See..
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
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
39
2
n -Hexane
110543
344
17
Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year
( b/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:
Process 01: Condensate loaded out from tanks to truck(s)
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
NOx
4.20 * 10-4
4.20 * 10-4
AP -42
CO
1.92 *10'
1.92 * 10.3
VOC
0.236
1.18 * 10-2
CDPHE
Benzene
71432
4.10 * 10-4
2.05 * 10-5
Page 9 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Enanronment
Dedicated to protecting and improving the health and environment of the people of Colorado
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
n -Hexane
110543
3.60 * 10 3
1.80 * 10"4
The uncontrolled VOC and HAP emission factors are based on the CDPHE approved state default values for
condensate loadout. The NOx and CO emission factors are based on the AP -42 Chapter 13.5 emission
factors for industrial flares and a waste gas higher heating value of 2,640 Btu/scf. Controlled emission
factors are based on a flare efficiency of 95% and a collection efficiency of 100%.
Process 02: Combustion of pilot light gas
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
68.0
68.0
AP -42 Chapter
13.5
CO
310.0
310.0
Note:
The NOx and CO emission factors listed in the table above were obtained by multip ying the AP -42
Chapter 13.5 emission factors (0.068 lb/MMBtu for NOx and 0.31 lb/MMBtu for CO) by a heat
value of 1,000 Btu/scf. Actual emissions are calculated by multiplying the emission factors in
the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on
a constant rate of 25 scf/hr. Monthly pilot light gas throughput shall be determined by
multiplying this hourly pilot gas throughput by the enclosed combustor monthly hours of
operation. There is one (1) enclosed combustor equipped with a single pilot light used to
control emissions from the truck loadout of condensate.
Total actual emissions are obtained from the sum of emissions resulting from the natural gas
generated from the truck loadout of condenste and routed to the enclosed combustor(s) (process
01) and the combustion of pilot light gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane
Page 10 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 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 11 of 11
Colorado Mr Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Ben Fischbach
Package#: 427572/434911
- Received Date: 6/11/2020
Review Start Date: 7/28/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC - Quadrant Section I Township I Range
County AIRS ID: 123 NENW 14 2N 68
Plant AIRS ID: 9E30
Facility Name: Grant Salisbury Elmquist 14H-0268 Battery
Physical
Address/Location: ,.
County: Weld County
Type of Facility. ,Exploration&Production Well Pad.
What industry segment?0 I&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 it
Emissions (Leave blank unless Issuance Self Cert
(Leave blank unless APCD Emissions Source Type Equipment Name :etntit
EgCD has already # RRmkhas alreag
001 Storage Tank - - TANKS Yes 15WE1413 - 3 Yes Modification
All new
conditions in
this permit will
also exist in
15WE1413,so
will not require
Permit self certification
002 - Storage Tank PW Yes 15WE1414 3 No Modification of this.ermit.
Added mid-
- service.
•
Permit Package
003 Liquid Loading LOAD-1 -Yes 15WE1415 3 Yes Modification 434911
Permit Initial.
014 Separator Venting Buffer Yes 20WE0606 1 Yes Issuance
Section 03-Description of Project
Applicant proposes the modification of the permits 15W11413,15WE1414,15W E1415,1415,and the permitting of a new separator venting point,covered under point
014 on permit 20WE0606..
Modification to 15WE1413 includes:New requested throughput limit,and new site specific emission factor based on the addition of tanks(from the existing point
005)to the battery.Tanks from point 005 merged due to removal of VRT upstream of those tanks.
Modification to 15WE1414 includes:Development'of new site-specific emission factor and removal of control device:
Modification to 15W01415 includes:New requested throughput limit,using 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
Point 014 has uncontrolled PTE>100 tpy,
Section 05-Ambient Air Impact Analysis Requirement so is requesting a syn minor permit.
Was a quantitative modeling analysis required? No
If yes,for what pollutants? _
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: sot NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) El
_
Title V Operating.Permits(OP) � — Q ® LI -
Non-Attainment New Source Review(NANSR) - �-
Is this stationary source a major source? No
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention Operating
of acing Permit Deterioration(PSD) —— El C
Title V Operating Permits(OP) It._
Non-Attainment New Source Review(NANSR)
Hydrocarbon Loadout Emissions inventory
Section 01-Administrative Information
003
Facility AIRs ID: 123 a,. 9E30 -
County Plant Point
Section 02-Equipment Description Details
•
Detailed Emissions Unit .joaaout of condensate from tanks to trucks. -
Description: - - -
Emission Control Device Ea)
Description: -
Isthisloadoutcontrolled? �"'z :•,
Requested Overall VOC&HAP Control Efficiency%: 95
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 79,690 Barrels(bbl)per year
Requested Permit Umit Throughput= 95,630 Barrels(hbl)per year Requested Monthly Throughput= 812= Barrels(bbl)per month '
Potential to Emit(PTE)Volume Loaded= 95,630 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2640 Btu/scf
Actual Volume of waste gas emitted per year= ,••7i,7,6 scf/year
Requested Volume of waste gas emitted per year= 2217€.5 scf/year
Actual heat content of waste gas routed to combustion device= MMBTU per year
Requested heat content of waste gas routed to combustion device= -;- MMBTU per year
Requested and PTE volumes updated to reflect operator's calculations,which are more
Potential to Emit(PTE)heat content of waste gas routed to combustion device= '.MMBTU per year conservative than the traditional PA method.
Control Device
Pilot Fuel Use Rate: 25 scfh .:.7?MMscf/yr
-Pilot Fuel Gas Heating Value: . .;t00b.Btu/scf _-) MMBTU/yr
Section 04-Emissions Factors&Methodologies
Does the company use the state default emissions factors to estimate emissions? '
Does the hydrocarbon liquid loading operation utilize submerged fill? •
::rr-� -. s - , ^• ^:.e ^
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Emission Factor Source
Pollutant
(lb/bbl) (lb/bbl)
(Volume Loaded) (Volume Loaded)
VOC 2 3 E-J: 1.18E C2 Condensate Loadout State E.F.
Benzene 4.13E14 2.05E 05 Condensate Loadout State E.F.
Toluene 3JOE ece 0 0E-0,3
Ethylbenzene COr 1- .7.00E sOI'
XYlene V'.!:CE-'' .30E.;•00
n-Hexane 1.30E C3 1.8CE 04 .d`ondensate Loadout State E.F.
224 TMP 3.OCE,27.
Control Device
Pollutant _ Uncontrolled Uncontrolled Emission Factor Source
(lb/MMBtu) (Ib/bbl(
(waste heat combusted) (Volume Loaded)
PM10 .,
PM2.5 0.2CE J;:
SOx J.00c+OC
NOx 0.0680 •I 2OE 0#7-42 thapter 13.5 Industrial Flares(NOx)
CO 7 03100 192 C3 '42-Chapter 13.5 Industrial Flares(CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant )Ib/MMBtu) (Ib/MMscf( Emission Factor Source
(Pilot Gas
(Waste Heat Combusted) Throughput)
PM10 , 3.2000
PM2.5 d 3000
500 - 0 0000
NOx - 0.0680 68 0000 AP-42 Chapter 13.5 l ndustria:Flares(NIOx)
VOC 3`7000
CO 0.3100 _ 3230000 AP-42 Chapter 13.5 Industrial Flares(COO
•
2 of 7 K:\PA\2015\15WE1415.CP3
Hydrocarbon Loadout Emissions Inventory
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)
PM10 0.00 0.00 _3, 0.00 0 0r. 3
PM2.5 0,00 0.00 0.00 C.33 3
SOx 0.00 .. _ 0:00 s.__
NOx 0.0 0.031 0.031 0.03 C.C3 -
VOC 10.20 4,13 0,40 1..., ,. vv
CO 0.1 0,14' 0._5 0.13 v_s __
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) fibs/year) fibs/year) (lbs/year) (Ibs/year)
Benzene 39 06 -5 35 2
Toluene 0 0 9 Operator based Acts.
Ethylbenzene - 0 0 emissions on(media,iy
Xylene C a approved emission factors,
n-Hexane - 1410 71 301 33- and actual t h `
224 TMP _ 1 r,..'
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,8 s a oerm;x
Regulation 7 Part D:Section II.C.b.. bon liquids E e..,source is 5 ubie(1 no Regulates 3 Poet D Sect,d4 II.;1.1.
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial.and Periodic Sampling and Testing Requirements FF
...6..,
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
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process# SCC Code Pollutant Factor Control% Units
003 01 - _ PM10 8 8.1 _ lb/1,000 gallons transferred
PM2.5 1.88 O lb/1,000 gallons transferred
SOx 0.05 0 lb/1,000 gallons transferred
NO0 8,81 0 lb/1,000 gallons transferred
VOC 5.5 i_ lb/1,000 gallons transferred
CO 0.06 3 lb/1,000 gallons transferred
Benzene r1 R1 95 lb/1,000 gallons transferred
Toluene 0.00 95 lb/1,000 gallons transferred
Ethylbenzene =8 50. 95 lb/1,000 gallons transferred
xylene 6 di— 95 lb/1,000 gallons transferred
n-Hexane _-16 40 lb/1,000 gallons transferred
224 TMP 6.._ `05 lb/1,000 gallons transferred
3 of K:\PA\2015\15WE1415.CP3
Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
ColorsioParts&5nd a.AP EN and Permit Requirements emIa surce Imo the Non Attainment.'Awe
ATIAINMENT
1. Are uncontrolled actual emissiens from anyodterla pollutants Porn this Individual source greater than 2TPY(Regulation 3,PartA,Section 11.63a1]
. Is the loadout located at an exploration and production site(AA,well pad)(Regulation 3,Part B,Section 11.0.1.1)]
3. Is the loadout operation loading less dun 10,000.gallons f230 333LN of crude oil per day on an annual average basis,
4. Is the loadout operation loading less than 3,750 bids per year of condensate via splash MIS
5. IS the loadout operation loading less than 16~00 NM per year of condensate via submerged fill procedure,
6 Prem.-facility uncontrolled V0C emissions greater than 5 TAY,NOx greater then 10 TPY orGo emissions greater Man lO TPY(Regulation 3,Part 0,Section
Iypu ha,ieint..dchatsomraS-=the Sso_tsNnmcar Arca .
NO NA fAM un
1.Are controlled emissions horn any criteria pollutanisbon this individual source greater(bent.,(Regulation 3,Parte,Section tl.O LaR Yea:.'t"Go to next question.
Is the...locatd at an exp Drat on and product ores to(e.g,well peg)(Regulation 3,Part B.Section Yes Go Au the next question
3. Is the loadout operation loading 10.000 sailors(238 Betel°lauded perday on an annual average basisi t Go M next question
4. Is the loadout operation loadrng lesa than 6,750 tools per year of condensate via splash MIT No' 5 Gob next question
5. Is theloadqut operation loading less than 16,300 tools per year of condensate Na submerged MI procedure] Nt, Go to next question
6 Are total fac'ty uncontrolled VOc emissions from the greater than 2 TPy,NON greater than 5 TPY a CO emssons greater than 10 TPY(Regulation 3,Part 0,Section II1121i Yes. t The loadout requires a permit
colored° rtlnll«.
this condense to storage tankhydrocarbon liquids loadout located at a well production facility,natural gas compressor s5tlan or natural gas processing plan[] Yes IGo to next question.
a.Does the hc ty have a MI oughputof hydrocarbon liquids loadout to transport vehicles greater than°sequel,51000 barrels] _. 'Source issublect to Regulation 7 Part 0 Sectionll.C.S
IB.Si ..sliculMImacut mtiwis suMwf.sgmatm Pert 0 asap,._Cs
section Il.esa.fil-Compliance Schedule •
54.53-opeation without Venting
Section II C3 x.63)-Loadout Equipment Operation and Maintenance
Yction PC S.ated-Ioado tobservations and Operator Training
h.C a.lv1-Records
Section II.e.5.5.aN31-Requirements for Nr Pollution Control Equipment
Disclaimer -
This document assists operators with determining applicability of certain',Rieman.W the Clean Air Act Rs implementing regulations,and Alr Quelity Control Commission regulations.This document is not e
rule or regulation.and the enebais itccnfains may not apply to a particular situation basal upon theirdrviduel facts end circumstances.This document does not charges substitute teeny law,regulation.w
any other legally biodrgrequirenent end is no legally eM eabk.In the event deny conflict between thekrgugged'thiscbcument end the languaged the Clean Air Act.,its impleentirgregultiau, •
and Air Quality Conte Commission regulations,the language rf the statute or regulation will conta.The use dnormapdatay language such as`recommend'pray.""shard,"and"can,"is intended to
descrthe APCD interpretations end recommendations.Mandatory terminology such ere'youWend tsquhred'are inrtsnd,to describe cartrdling requirements under the tens d the Clean Apart ardAir
Queiify Control Commission regulations,but this document area not establish legadybindeg a utlements in and difsed.
•
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123 History File Edit Date 913012020
Plant AIRS ID 9E30 Ozone Status Non-Attainment
Facility Name Grant Salisbury Elmquist 14H-C268
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 0.2 0.2 0.0 0.0 17.7 1,712.3 2.2 32.5 81.6 0.2 _ 0.2 0.0 0.0 4.2 , 86.7 2.2 14.3 4.4
Previous Permitted Facilit/total 0.2 0.2 0.0 0.0 10.4 1,711.9 2.2 24.2 81.5 0.2 0.2 0.0 0.0 3.3 86.3 2.2 12.5 4.3 ,
001 15WE1413 26-Condensate Tanks(receives liquids from 0.0 0.0 0.9 522.0 4.3 18.1 0.0 0.0 0.9 26.1 4,3 0.9 Modification-merging with point 001,updating EF
002 15WE1414 7-Produced water storage tanks 1.2 0.4 1.2 0.4 Modification to reduce throughput
003 15WE1415 Condensate Loadout 0.0 11.3 0.1 0.2 0.0 0.6 0.1, 0.0,Modification to reduce throughput
004 15WE1416 Fugitive Component Leaks 2.2 0.3 2.2 0.3
005 15WE1413.CN 8-Condensate Tanks(w/o benefit of VRT) 0.0 _ - 0.0 Cancellation received 5/18/2020-Point no longer exists
' (merged with point 001 upon issuance of 15WE1413)
006 16WE0801.CN COMP-1 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
007 16WE0862,CN COMP-2 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
008 16WE1072.CN 0.0, 0.0 Cancellation received 5/29/2019-Point no longer exists.
009 18W50514.CN 0.0 0.0 Cancellation received 5/2912019-Point no longer exists.
010 1•8WE0514.CN 0,0 0.0 Cancellation received 5/29/2019--Point no longer exists.
011 •GP02 CN • PSI,1 , , 0 0 0.0 Cancellation received.5/29/2019-Point no longer exists.
012 18WE1122.XP COMP-4 7.3 0.40 8.3 0.1 0.9 0,4 1.8 0.1
013 GP02 GM-1(GM Vortec 5.7L,92hp,sn:158D7167) 0.100 0.100 8.0 0,6 13.5 0.1 0.100 0.100 0.9 0.6 1.8 0.0
014 20WE0606 LP Gas Vented from HLP Separators 0.40 162.20 1.80 5.5 0.40 8.10 1.80 0.0 New point
FACILITY TOTAL 0.1 0.1 0.0 0.0 16.6 697.7 2.2 28.0 24.7 0.1 0.1 0.0 0.0 3.1 37.0 2.2 9.8 1.7 VOC: Syn Minor(NANSR and OP)
NOx:Minor(NANSR and OP)
CO: Minor(PSD and OP)
HAPS: Syn Minor n-hexane
•
HH: Syn Minor
7777: Area
Permitted Facility Total 0.1 0.1 0.0 0.0 8.5 372.9 2.2 16.1 24.6 0.1 0.1 0.0 0.0 2.2 36.6 2.2 8.0 1.6 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.1 -0.1 0.0 0.0 -1.1 -49.7 0.0 -4.5 Pubcom&modeling not required based on change of
emissions from construction permit sources.
Total VOC Facility Emissions(point and fugitive) 39.2 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -49.7 Project emissions less than 25/50 tpy
Note 1
Note 2
Page 5 of 7
Printed 9/30/2020
•
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 3337 3137 146 899 28689 54 18.1
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 39 344 0.2
004 15WE1416 Fugitive Component Leaks 39 42 22 230 225 0.3
005 15WE1413.ON 8-Condensate Tanks(w/o benefit of VRT) 0.0
006 16WE0861.CN COMP-1 0.0
007 16WE0862.CN COMP-2 0.0
008 16WE1072.CN 0.0
009 18WE0514.CN 0.0
010 18WE0514.CN 0.0
011 GP02.CN PSI-1 0.0
012 18WE1122.XP COMP-4 89 12 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,an: 158D7167) 149 20 19 11 4 1 22 0.1
014 20WE0606 LP Gas Vented from HLP Separators 1001 1002 48 343 8671 5 5.5
TOTAL(tpy) 0.0 0.0 0.0 1.8 1.7 0.1 0.6 14.7 0.0 0.0 _ 0.0 _ 0.0 19.0
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de minimus
6 15WE1415.CP3 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
Emissions with controls(lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethyibenzene 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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 167 157 7 45 1434 3 0.9
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 2 . 17 57 0.0
004 15WE1416 Fugitive Component Leaks 39 42 22 230 225 0.3
005 15WE1413.CN 8-Condensate Tanks(w/o benefit of VRT) 0.0
006 16WE0861.CN COMP-1 0.0
007 16WE0862.CN COMP-2 0.0
008 16WE1072.CN • 0.0
009 18WE0514.CN 0.0
010 18WE0514.CN 0.0
011 GP02.CN PSI-1 0.0
012 18WE1122.XP COMP-4 89 12 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,sn: 158D7167) 149 20 19 11 4 1 22
014 20WE0606 LP Gas Vented from HLP Separators 50 50 2 17 434 1
TOTAL(tpy) 0.0 0.0 0.0 0.2 0.2 0.0 0.2 1.0 0.0 0.0 0.0 0.0 1.7
I
7 15WE1415.CP3 9/30/2020
COLORADO
Air Pollution Control Division
Department cf Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
20WE0606 Issuance: 1
Crestone Peak Resources Operating, LLC
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Grant Salisbury Elmquist 14H -C268 Battery
123/9E30
NENW Section 14 T2N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Buffer
014
Flaring of natural gas vented from one (1)
bulk separator and from the low pressure
side of (12) high/low pressure (HLP)
separators and routed through the buffer
house during vapor recovery unit (VRU)
downtime.
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS) form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part -B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
Page 1 of 10
COLORADO
Ito, Air Pollution Control Division
I
Department of Pubic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.00v/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,t
VOC
CO
BUFFER
014
---
---
8.1
1.8
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder must
Page 2 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
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 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.
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
Point
Control Device
Pollutants
Controlled
BUFFER
014
Emissions from the bulk separator and the
twelve (12) high/low pressure (HLP)
separators are routed through the buffer
house to enclosed combustor(s) during
vapor recovery unit (VRU) downtime.
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,
I.A.4. )
Process Limits
Equipment
ID
AIRS
Point
Process
Process Parameter
Annual
Limit
BUFFER
014
01
Natural gas vented from the low
pressure side of the HLP
separators and routed through
the buffer house to the enclosed
corbustor(s)
5.76 MMSCF
02
Combustion of pilot light gas
0.22 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.
Page 3 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
10. The owner or operator must continuously monitor and record the volumetric flow rate of
natural gas vented from the bulk separator and the low pressure side of the HLP separators
and routed through the buffer house to the enclosed combustor(s) using an operational
continuous flow meter. The flow meter must be calibrated and maintained per the
manufacturer's specifications and schedule. The owner or operator must use monthly
throughput records to demonstrate compliance with the process limits contained in this
permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III. E.) (State only enforceable)
12. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
13. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II. B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto -igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
14. The separators covered by this permit are 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)
Page 4 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
OPERATING a MAINTENANCE REQUIREMENTS
16. 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
17. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
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 NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on
the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
Page 5 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
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. 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 application for the Operating
Permit is due within one year of the earliest commencement of operation of any piece of
equipment covered by this permit.
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II. B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
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.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
Page 6 of 10
aNtgo
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Crestone Peak Resources Operating,
LLC.
Permit for flaring of low pressure gas vented
from the low pressure side of HLP separators at
an existing well production facility.
Page 7 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
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
ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
SEP-1
001
Benzene
71432
1,001
50
Toluene
108883
1,002
50
Ethylbenzene
100414
48
2
Xylenes
1330207
343
17
n -Hexane
110543
8671
434
2,2,4-
Trimethylpentane
540841
5
<1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
w. ire
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Process 01: Natural gas vented from the bulk separators and from the low pressure side of the
HLP separators and routed through the buffer house to the enclosed combustor(s
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMscf)
Controlled
Emission
Factors
(tb/MMscf)
Source
NOx
135.86
135.86
AP -42
CO
619.38
619.38
VOC
56,353
2817.65
Extended Gas
Analysis
71432
Benzene
174
8.70
108883
Toluene
174
8.70
100414
Ethylbenzene
8.23
4.12 * 10.1
1330207
Xylene
59.57
2.98
110543
n -Hexane
1,506
75.30
540841
2,2,4-
Trimethylpentane,
0.83
4.15* 10"2
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
The emission factors listed above are based on an extended gas analysis of the Buffer House Gas at the Grant
Salisbury Elmquist 14H -C268 Facility. Sample was collected on 4/22/2020 at a separator pressure of 22.8 psig
and a temperature of 80 °F, and was analyzed on 4/23/2020. Combustion emissions are based on a higher
heating value of 1998 Btu/scf, as reported by the gas analysis.
Process 02: Combustion of pilot light gas
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
NOx
68.0
68.0
AP -42 Chapter
13.5
CO
310.0
310.0
Note:
The NOx and CO emission factors listed in the table above were obtained by multip ying the AP -42
Chapter 13.5 emission factors (0.068 lb/MMBtu for NOx and 0.31 lb/MMBtu for CO) by a heat
value of 1,000 Btu/scf. Actual emissions are calculated by multiplying the emission factors in
the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on
a constant rate of 25 scf/hr. Monthly pilot light gas throughput shall be determined by
multiplying this hourly pilot gas throughput by the enclosed combustor monthly hours of
operation. There is one (1) enclosed combustor equipped with a single pilot light used to
control emissions from the low pressure side of the high/low pressure separators.
Page 9 of 10
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
Total actual emissions are obtained from the sum of emissions resulting from the natural gas
vented from the low pressure side of the HLP separators and routed through the buffer house to
the enclosed combustor(s) (process 01) and the combustion of pilot light gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, n -Hexane
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
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
63.1.200-63.1439
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 St: 427572/434911
Received Date: 6/11/2020
Review Start Date. 7/28/2020
Section 01-Facility Information
Company Name: Crestone Peak Resources Operating,LLC Quadrant' Section I Township Range
County AIRS ID. 123 :NENW 11 14 2N 68
Plant AIRS ID: 9E30
Facility Name: Grant Salisbury Elmquist 1411-C268 Battery
Physical
Address/Location: _
County: Weld County
Type of Facility: Exploration&Production Well Pad-
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRS Point 0 Permit 0
Emissions (Leave blank unless Issuance Self CeH Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action-
has already assigned) Control? APCD has already g Required? Remarks
signed)
Permit
001 -Storage Tank TANKS :. Yes 15WE1413 -'3 Yes Modification
All new
conditions in
this permit will
also exist in
15WE1413,so
will not require
Permit self certification
002 Storage Tank PW Yes 15WE1414 3 No Modification of this permit.
- - Added mid-
... service.
Permit Package
003 Liquid Loading LOAD-1 Yes 15WE1415 3 Yes Modification 434911
Permit Initial
014 - Separator Venting Buffer Yes 20WE0606 1 Yes Issuance
Section 03-Description of Project
Applicant proposes the modification of the permits 15WE1413,15WE1414,15WE141S,and the permitting of a new separator venting point,covered under point
014 on permit 20WE0606.
Modification to 15WE1413 includes:New requested throughput limit,and new sue specific emission factor based on the addition of tanks(from the existing point
005)to the battery.Tanks from point 005 merged due to removal of VRT upstream of those tanks.
Modification to 15WE1414 includes:Development of new site-specific emission factor and removal of control device.
Modification to 15WE1415 includes:New requested throughput limit,using State default emission factors.
r w Sections 04,05&06 For Division Use Only
,-w
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Point 014 has uncontrolled PTE>108 tpy,
Section 05-Ambient Air Impact Analysis Requirement so is requesting a syn minor permit:
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 500 CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant.Deterioration(PSD) ./
Title V Operating Permits(OP) E __ E 1 El e ® ❑✓
Non-Attainment New Source Review(NANSR) J
Is this stationary source a major source? No
If yes,indicate programs and which pollutants: SO2 NOx co VOC PM2.5 PM10 TSP HAPs
Prevention V Operating
of sting t Deterioration(PO) E - ® n - ® ❑
Title V Operating Permits(OP) C�_lr
Non-Attainment New Source Review(NANSR)
•
Separator.Vfnting Emissions inventory
Section 01-Administrative Information
123 9E30 014
Facility Allis ID: -
County Plant Point
•
Section 02-Equipment Description Details
Buffer(separator)gas venting controlled by enclosed combustor
Detailed Emissions Unit Description:
ECD
Emission Control Device Description:
Requested Overall VOC&HAP Control Efficiency%: 95
Limited Process Parameter paturelt=.„as V nted -
Gas meter „_„ a eprrently,insta(led and operational
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= : 0.0 MMscf per year
Requested Permit Limit Throughput= 5.757 MMsd per year Requested Monthly Throughput= 0.5 MMscf per month
Potential to Emit(PTE)Throughput= 5.8 MMsd per year
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: 1998.0..Btu/scf
Volume of waste gas emitted per BBL of
liquids throughput: scf/bbl
Control Device
Pilot Fuel Use Rate: 25 sdh 0.22 MMsd/yr
Pilot Fuel Gas Heating Value: qty 1000 Btu/scf
7r
Section 04-Emissions Factors&Methodologies
Description
Emission factors are based on an extended gas analysis of the Buffer house gas at the Grant Salisbury Elmquist 14H-C268 Facility.Sample was collected on 4/22/2020 at a pressure of 22.8 psig and a temp of 80F,and analyzed
4/23/20.
MW I 35.1552 Ib/Ib-mol Displacement Equation
Ex=Q.MW s Xx/C
Weight%
Helium 0.0590
CO2 2.5052
N2 - 0.2032
methane 15.9775
ethane 20.5018
propane 24.4678
isobutane 5.3046
n-butane 13.9089
Isopentane 4.2780
n-pentane 5.1411
cyclopentane 0.2913
n-Hexane '.1.6237
cyclohexane - 0.4250
Other hexanes 2.5849
heptanes 1.0410
methylcyclohexane 0.4355
224-IMP 0.0009
Benzene ..0.1875
Toluene 0.1876
Ethylbenzene 0.0089
Xylenes 0.0642
C8+Heavies 0.8025
Total
VOC Wt%
2 of 8 K:\PA\2020\20WE0606.CP1 -
Separator`-Jertivr E.iT,s ior)s inventory
Emission Factors Separator Venting
Uncontrolled Controlled _
Emission Factor Source
Pollutant (lb/MMscf) (Ib/MMscf)
(Gas Throughput) (Gas Throughput) AP EN LISTED
VOC -3 .. 57__3 - . .y �.. 56353 2817.65
Benzene ,,.i. - 174 8.70
Toluene a`- S C-- VECEPECR.L - •
174 8.70
Ethylbenzene ._.._. _.4=.z= _ 8.23 4.12E-01
Xylene S3w505 ,..5,:_ _ - 59.57 2.9785
n-Hexane 1556.1381 7;.3.334 sE 1506 75.30
224TMP 0.334£ aAR- W 0.83 4.15E-02
Primary Control Device
Uncontrolled Uncontrolled AP EN listed values are within rounding error,and will be used in permit.
Pollutant (lb/MMBtu) Ib/MMscf Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
PM10 _ '•J3
PM2.5 c coo:
SOx €, _....
NOx 0.0680 a .
CO 0.3100. .. Y4:2 C)bad '1,7._. taFFf '$',: a
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MM Btu) Ib/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10 6.13000 sue• .,.01.11, «.
PM2.5 >L-33
Sox 3.aeor
NOx 0.0530 SS.7000
VOC 0.60=O
CO 0,3100. _ ,616 CC.S3 ''�..f' i k+:.
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)
PM10 0.3 3.3 6.*
PM2.5 0,0 5.3 _.c u._ e
sox B.0 7.0 0.0 0.0 .._
NOx 3.33 03.0 0.40 _..-> 68
VOC . 162,7 0.0 _., °62.22 3. r _378
CO 1._ 3,0 0.0 1.86 1,8:1 309
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (Ibs/year) (lbs/year) (lbs/year) (Ibs/year)
Benzene 1001 3 0 i032 50
Toluene 1002 a c 2002. >_
Ethylbenzene 41 3 0 SS 5 1.6
Xylene 343 0 0 1,
n-Hexane 3°71 0 o 8672. 434
224TMP I 0 0 4.,. 0,2
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,8 .;v...se requlzns a permit
Regulation 7,Part D,Section 11.8,F Ss,..e is sublect TO Regulation 7,Pat,-S=ct1,a_
Regulation 7,Part D,Section 11.8.2.e :6'4,60'6.01'cstte fur=.hls separator t t sua; -!at!os 7.Part D,Section€1.8 2.e
(See regulatory applicability worksheet for detailed analysis)
•
3 of 8 K:\PA\2020\20WE0606.CP1
i
Separator Venting-Emissions inventory
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?
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 180
days).This condition will use the"Volume of waste gas emitted per BBL of liquids throughput"(scf/bbl)value in section 03.
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
k� ,.� j.. fr ..x
a
r..Y,M1fitil i r i
Section 08-Technical Analysis Notes
•
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only).
AIRS Point 8 Process it SCC Code Pollutant Uncontrolled Emissions Factor Control% Units
014 01 -:t•i0'c.3•:,.a.-'- PM10 :. 0 443,0,7,
PM2.5
SOx
NOx
VOC
CO _,_. ., ,.,5I.rt3c
Benzene t.. ...
Toluene
Ethylbenzene
Xylene _ 3b iv.'v`�a5;:t
n-Hexane ,h:
224TMP
4 of 8 KSPA\2020\20WE0606.CP1
Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and R-APEN and Permit Requirements
ATTAINMENT
eg
¢
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY(Regulation 3,Part A,Section 11.0.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY NOK greater than 10TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.31? r
IYou have nziketed May source isI She-'vasu?tai e trva_
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section ll.D.1.a)? Yes Source Re
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY,NOz greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.21? Yes Source Re
'Source e __ ....
Colorado Regulation 7,Part D,Section I1
1. Was the well newly constructed,hydraulically f t d or recompleted on or after August 1,2014? Yes 'Source is.
'Sou,.is subject to ,
Section 11.8.2—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 o t ll d by a back-up It k combustion device(Le.,not the primary control deuce)that is not enclosed? OMIAThe cantr,
go, ncCsra. ocA gn,!..tion,Part V_a.".1Eorrh.R.2.c
Section II.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations This document is
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"em 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,Inc.
County AIRS ID 123 History File Edit Date 913012020
Plant AIRS ID 9E30 Ozone Status Non-Attainment
Facility Name Grant Salisbury Elmquist 14H-C268
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 142S 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 0.2 0.2 _ 0.0 0.0 17.7 1,712.3 2.2 32.5 81.6 0.2 0.2 0.0 0.0 4.2 86.7 2.2 14.3 4.4
Previous Permitted Facilititotal 0.2 0.2 0.0 0.0 10,4 1,711.9 2.2 24.2 81.5 0.2 0.2 0.0 0.0 3.3 86.3 2.2 , 12.5 4.3
001 15WE1413 26-Condensate Tanks(receives Squids from 0.0 0.0 0.9 522.0 4.3 18.1 0.0 0.0 0.9 26.1 4.3 0.9 Modification-merging with point 001,updating EF
002 15WE1414 7-Produced water storage tanks 1.2 0.4 1.2 0.4 Modification to reduce throughput
003 15WE1415 Condensate Loadout 0.0 11.3 0.1 0.2 0.0 0.6 0.1 0.0 Modification to reduce throughput
004 15WE1416 Fugitive Component Leaks 2.2 0,3 2.2 0 3
865 i5WW147S:CM 8-Condensate Tanks fyi/o benefit of VRT) 0,0 0.0 Cancellation received 5/16/2020-Point no longer exists
(merged with point 001 upon issuance of 15WE1413)
006 16WE0861.CN COMP-1 00 • 0.0 Cancellation received 5/29/2019-Point no longerexists.
007 16W60862 CN COMP-2 0.0 0.0.Cancellation received 5/29/2019-.Point no longer exists.
008 16WE1072 ON 0.0 0.0 Cancellation received 5/29/2019-Point no longer exists.
009 15WE0514.CN 0.0 0:0 Cancellation received 5/29/2019-Point no longer exists.
010 18WE0514,Cty 0,0 0,0 Cancellation received 5/29/2019-Point no longer
011 GP02.CN PSI-1 0.0 0.0 Cancellation received 5/29/2019 Point no longer exists.
012 18WE1122.XP COMP-4 7.3 0.40 8.3 0.1 0.9 0.4 1.8 0.1
013 GP02 GM-1(GM Vortec5.7L,92hp,sn:15807167) 0.100 0.100 8.0 0.6 13.5 0.1 0.100 0.100 0.9_ 0.6 1.8 0.0
014 20WE0606 LP Gas Vented from HLP Separators 0.40 162.20 1.80 5.5 _ 0.40 8.10 1.80 0.0 New point
FACILITY TOTAL 0.1 0.1 0,0 0.0 16.6 697.7 2,2 28.0 24.7 0.1 0.1 0.0 0.0 3.1 37.0 2,2 9.8 1.7 VOC: Syn Minor(NANSR and OP)
NOx:Minor(NANSR and OP)
CO: Minor(PSD and OP)
_ HAPS: Syn Minor n-hexane
HH: Syn Minor
7777: Area
Permitted Facility Total 0.1 0.1 0.0 0.0 8.5 372.9 2.2 16.1 24.6 0.1 0.1 0.0 0.0 2.2 36,6 2.2 8.0 1.6 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.1 -0.1 0.0 0.0 -1.1 -49.7 0.0 -4.5 Pubcom&modeling not required based on change of
emissions from construction permit sources.
Total VOC Facility Emissions(point and fugitive) 39.2 Facility is eligible for GP02 because<90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -49,7 Project emissions less than 25/50 tpy
Note 1 •
Note 2 _
•
Page 6 of 8 J Printed 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 3337 3137 146 899 28689 54 18.1
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 39 344 0.2
004 15WE1416 Fugitive Component Leaks 39 42 22 230 225 0.3
005 15WE1413.CN 8-Condensate Tanks(w/o benefit of VRT) 0.0
006 16WE0861.CN COMP-1; 0.0
007 16WE0862,CN COMP-2 0.0
008 16WE1072.CN 0.0
009 18WE0514.CN 0.0
010 18WE0514.CN 0.0
011 GP02.CN PSI-1 0.0
012 18WE1122.XP COMP-4 89 12 11 7 2 1 13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp,sn: 158D7167) 149 20 19 11 4 1 22 0.1
014 20WE0606 LP Gas Vented from HLP Separators 1001 1002 48 343 8671 5 5.5
TOTAL(tpy) 0.0 0.0 0.0 1.8 1.7 0.1 0.6 14.7 0.0 0.0 0.0 0.0 19.0
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de minimus
7 20WE0606.CP1 9/30/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,Inc.
County AIRS ID 123
Plant AIRS ID 9E30
Facility Name Grant Salisbury Elmquist 14H-C268
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 15WE1413 26-Condensate Tanks(receives liquids from VRT) 167 157 7 45 1434 3 0.9
002 15WE1414 7-Produced water storage tanks 270 203 6 38 229 0.4
003 15WE1415 Condensate Loadout 2 17 57 0.0
004 15WE1416 Fugitive Component Leaks 39 42 22 230 225 0.3
005 15WE1413.CN 8-Condensate Tanks(w/o benefit of VRT) 0.0
006 16WE0861.CN COMP-1 0.0
007 16WE0862.CN COMP-2 0.0
008 16WE1072.CN 0.0
009 18WE0514.CN 0.0
010 18WE0514.CN 0.0
011 GP02 CN PSI-1 0.0
012 18WE1122.XP COMP-4 89 12 11 '7 2 1 '13 0.1
013 GP02 GM-1 (GM Vortec 5.7L,92hp, sn: 158D7167) 149 _ 20 19 11 4 1 22
014 20WE0606 LP Gas Vented from HLP Separators 50 50 2 17 434 1
TOTAL(tpy) 0.0 0.0 0.0 0.2 0.2 0.0 0.2 1.0 0.0 0.0 0.0 0.0 1.7
8 20W E0606.CP1 9/30/2020
Condensate Storage Tank(s) APEN RECEIVED
Form APCD-205 JUN
Ctris
Air Pollutant Emission Notice (APEN) and APCD
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 15WE1413
AIRS ID Number: 123 / 9E30 / 001
l _ _ ;APCC,
C,
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Grant Salisbury Elmquist 14H -C268 Battery
Site Location: NENW, Section 14, T2N, R68W
Mailing Address:
(Include Zip Code) 10188 East 1-25 Frontage Road
Firestone, CO 80504
Site Location
County: Weld
NAICS or SIC Code: 1311
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.
421570
COLOR ADO
Form APCD-205 - Storage Tank(s) A Et _..,
12;2019
Page 5 of 82
Permit Number: 15WE 1413
AIRS ID Number: 123 19E30/001
3!1`, Unl _5_: AP(1 _ `D]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
❑ Request coverage under traditional construction permit
O Request coverage under a General Permit
O GP01 O GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
J MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name3
❑✓ Change permit limit ❑ Transfer of ownership4 O Other (describe below)
-OR -
❑ 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 Et Notes: Providing revised site -specific emission factor.
Combining AIRS points 001 and 005 with an increased throughput and removal of VRT.
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: 07/18/2015
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7
Storage tank(s) located at: ❑✓ Exploration & Production (E&P) site
days/week 52 weeks/year
O Midstream or Downstream (non E&P) site
Will this equipment be operated in any NAAQS nonattainment area?
O
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
O
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
■
Yes
❑✓
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)
805 series rules? If so, submit Form APCD-105.
Yes
No
0
I
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
0
COLORADO
Form AnCD 2 i. - Condensate Sto ,e Revision 12/2019
Page 6 of 82
❑ Upward
0 Horizontal
Permit Number: 15jWE 1413
AIRS ID Number: 123 /9E30/001
Section 4 - Storage Tank(s) Information
Condensate Throughput:
Actual Annual Amount
(bbl/year)
56,164
Requested Annual Permit Limits
(bbl/year)
95,630
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 60.8 degrees
❑ Internal floating roof
Tank design: 0 Fixed roof
RVP of sales oil: 12.5
0 External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TANKS
26
13,000
07/2015
07/2015
Wells Serviced by this Storage Tank or Tank Battery6 (EftP Sites On
y)
API Number
Name of Well
Newly Reported Well
05
- 123
- 37652
Grant Elmquist 2A -14H C268
■
05
- 123
- 37650
Grant Elmquist 2B -14H C268
■
05
- 123
- 37644
Grant Elmquist 2C -14H C268
■
05
- 123
- 37643
Grant Elmquist 2D -14H C268
■
05
- 123
- 37646
Grant Elmquist 2E -14H C268
■
s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 The EaP 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)
40.143677; -104.974286
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
ID No.
Discharge Height Above
Ground Level (Feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
0 Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
0 Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
F im APC.D 2i,; C nden': to Storage -
I APEN RPvislcn 12,2019
COLORADO
Page 7 of 82
Permit Number: 15VVE 1413
AIRS ID Number:
123 19E30/001
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 .
Vapor
O Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: NA
MMBtu/hr
Type: Enclosed Combustor Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: NA
NA
Waste Gas Heat Content:
Constant Pilot Light: ✓❑ Yes 0 No Pilot Burner Rating:
2,640
0.025
Btu/scf
MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
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)? 40 psig
Describe the separation process between the well and the storage tanks: Wellhead production to
high -low pressure three-phase separator, high-pressure gas to sales, low-pressure gas to
enclosed combustor. Condensate and produced water to storage tank battery.
Form APCD-2O5 - Condensate S_ a _ la ! PEN! E ,w si ss 12/21119
Page 8 of 82
Permit Number: 15WE1413
AIRS ID Number: 123 /9E30/001
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Q 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 Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
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:
Pollutant
Emission Factor7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
10.91
Ibabl
Site Specific
19.10
0.96
521.66
26.08
NO„
0.068
lb/MM8tu
AP -42
0.59
-
0.93
CO
0.31
Ib/MMBtu
AP -42
-
2.68
-
4.26
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.
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-criteriaEl 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 Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor7
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
Ohs/year)
Controlled
Emissions8
Ohs/year)
Benzene
71432
3.49E-02
Ib/bbe
Site Specific
118
5.9
Toluene
108883
3.28E-02
Ib/bbi
Site Specific
247
12.4
Ethylbenzene
100414
1.53E-03
lb/bbl
Site Specific
331
16.6
Xylene
1330207
9.40E-03
Ib/bbl
Site Specific
191
9.5
n -Hexane
110543
3.00E-01
Ib/bbl
Site Specific
1,769
88.5
2,2,4-Trimethylpentane
540841
5.65E-04
Ibibbl
Site Specific
107
5.3
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.
Form APCD-2O5 Condensate Storage Tank( st
pEr]
?2'2019
5 jCOLORADo
5 I I Wok%sb u rnt
Page 9 of 82
Permit Number: 15WE1413
AIRS ID Number: 123 19E30/001
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
• 06/11/2020
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
❑ 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
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-205 Conde..i ite Storage _cR..vi ao 12,'_.,..
co IORADO
6 I D.o.M..a.,.,r
ewn• a um..rt
Page 10 of 82
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Crestone Peak Resources Operating, LLC
Source Name:
Grant Salisbury Elmquist 1411-C268 Battery
Emissions Source AIRS Ill2:
123 / 9E30 / 001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 37645
Grant Elmquist 2F -14H C268
❑
05 - 123 - 37647
Grant Elmquist 2G-1411 C268
❑
05 - 123 - 37660
Grant Salisbury 2A -14H C268
❑
05 - 123 - 37658
Grant Salisbury 2B -14H C268
❑
05 - 123 - 37657
Grant Salisbury 2C-1411 C268
❑
05 - 123 - 37659
Grant Salisbury 2D-1411 C268
❑
05 - 123 - 37656
Grant Salisbury 2E -14H C268
❑
05 - 123 - 37654
Grant Salisbury 2F-1411 C268
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
■
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
Bib-APEN FORM 212 - Wellsite Addendum
Page 11 of 82
Produced Water Storage Tank(s) APF TcEVED
Form APCD-207
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
JUN 1 1 2020
CDPHE
APCD
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 15WE1414>>Exempt
AIRS ID Number: 123 / 9E30 / 002
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Grant Salisbury Elmquist 14H -C268 Battery
Site Location: NENW Section 14, T2N, R68W
Mailing Address:
(Include Zip Code) 10188 East 1-25 Frontage Road
Firestone, CO 80504
Site Location
County: Weld
NAICS or SIC Code: 1311
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.
Form APCD-207 . P oduc ,1 _.
ApEN R ,tsIon
gel toi.oRA DO
Page 12 of 82
Permit Number: 15WE1414>>Exempt
AIRS ID Number: 123 /9E30/002
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
O Request coverage under traditional construction permit
O Request coverage under a General Permit
❑ GP05 O GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
Q MODIFICATION to existing permit (check each box below that applies)
dQ Change in equipment
O Change permit limit
❑ Change company name3
O Transfer of ownership'
OR
Other (describe below)
❑ 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 £t Notes: Providing site specific emission factor, removal of
control device and cancellation of permit as PTE are below permit required threshold.
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:
Produced Water Storage Tanks
Company equipment Identification No. (optional): PW
For existing sources, operation began on: 07/18/2015
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week
Q Exploration Et Production (E&P) site
52
weeks/year
O Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
p
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
■
Yes
13
No
Are these storage tanks located at a commercial facility that accepts oil production•
wastewater for processing?
Yes
El
No
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
■
Yes
❑✓
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)•
805 series rules? If so, submit Form APCD-105.
Yes
No
SI
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual•
emissions ≥ 6 ton/yr (per storage tank)?
Yes
0
No
/APC 207 - Vy 3t'- r _'�r.,_ tii,;(s,i rPEN
2i
SC
ICOlORADO
xs m,..nt
Page 13 of 82
❑ Upward
O Horizontal
Permit Number: 15WE1414>>Exempt
AIRS ID Number: 123 /9E30/002
Fol. and AIRS la]
Section 4 - Storage Tank(s) Information
Produced Water Throughput:
Actual Annual Amount
(bbl/year)
29,796
Requested Annual Permit Limits
(bbUyear)
35,770
From what year is the actual annual amount?
Tank design: ✓❑ Fixed roof
2019
O Internal floating roof
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
PW
7
1,750
07/2015
07/2015
Wells Serviced by this Storage Tank or Tank Battery6 (EftP Sites On y)
API Number
Name of Well
Newly Reported Well
05
- 123
- 37652
Grant Elmquist 2A -14H C268
■
05
- 123
- 37650
Grant Elmquist 2B -14H C268
■
05
- 123
- 37644
Grant Elmquist 2C -14H C268
■
05
- 123
- 37643
Grant Elmquist 2D -14H C268
■
05
- 123
- 37646
Grant Elmquist 2E -14H C268
■
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)
40.143677; -104.974286
❑✓ 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
ID No.
Discharge Height Above
Ground Level (Feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
O Downward
o Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
Interior stack diameter (inches):
Interior stack width (inches):
O Upward with obstructing raincap
Interior stack depth (inches):
F- n Ar'CG 2 7- rr p ester
COLORADO
3 I D"""ll %NW
when. Dx.vvn,.N
Page 14 of 82
Permit Number: 155WE 1414>>Exempt
AIRS ID Number: 123 /9E30/002
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 .
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented):
_ ❑ Combustion
Device:
Pollutants Controlled:
Rating: MMBtu/hr
Type: Make/Model:
Requested Control Efficiency: %
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating:
Btu/scf
MMBtu /hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E6tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 40 psig
Describe the separation process between the well and the storage tanks: Wellhead production to
high -low pressure three-phase separators, high-pressure gas to sales, low-pressure gas to
enclosed combustor. Condensate and produced water to storage tank battery.
o r. APC[) F'2.077.- P
ge T nk,, s 1 APE ! 1,'„ejsion 12/2019
Hoag. Greta.*
4 , gM Hoag`"OL'""«,
Page 15 of 82
Permit Number: 15WE1414>>Exempt
AIRS ID Number: 123 /9E30/002
ARS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? O Yes fJ 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 Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
VOC
NOx
CO
HAPs
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:
Pollutant
Emission Factor7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP 42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
O062 0.0695
Ib/bbl
Site Specific
3.90
0.20
1.-40 1 24
NA
NOx
0.068
Ib/MMBtu
AP -42
—
0.02
NA
NA
CO
0.31
Ib/MMBtu
AP -42
—
0.07
NA
NA
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 produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
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 -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑✓ Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor7
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(lbs/year)
Controlled
Emissions8
(lbs/year)
Benzene
71432
0.007
lb/bbl
Site Specific
209
10.4
Toluene
108883
-
-
Ethylbenzene
100414
-
-
Xylene
1330207
-
-
n -Hexane
110543
0.006
lb/bbl
Site Specific
656
32.8
2,2,4-Trimethylpentane
540841
-
-
7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
For -r-, -, PC Produced L_
I _ nh(s) r E - 1_
�!► icoEo�Aoo
5 "__,
-BF
8/6/2020
Per attached email
Page 16 of 82
Permit Number: 15WE1414>>Exempt
AIRS ID Number:
123 19E30/002
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
."
06/11/2020
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:
Ej Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
9CD-207 -
Storage 1 nks) APEN., i n 172/2019 6
® I COLORADO
Mw4Ti Nuw�mt
Page 17 of 82
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
Crestone Peak Resources Operating, LLC
Source Name:
Grant Salisbury Elmquist 14H -C268 Battery
Emissions Source AIRS ID2:
123 / 9E30 / 002
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 37645
Grant Elmquist 2F -14H C268
❑
05 - 123 - 37647
Grant Elmquist 2G -14H C268
❑
05 - 123 - 37660
Grant Salisbury 2A-1411 C268
❑
05 - 123 - 37658
Grant Salisbury 2B -14H C268
❑
05 - 123 - 37657
Grant Salisbury 2C-1411 C268
❑
05 - 123 - 37659
Grant Salisbury 2D -14H C268
❑
05 - 123 - 37656
Grant Salisbury 2E-I4H C268
❑
05 - 123 - 37654
Grant Salisbury 2F-1411 C268
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
■
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
' 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
B2b-APEN FORM 212 - Wellsite Addendum
Page 18 of 82
9/30/2020 State.co.us Executive Branch Mail - COGA Priority Project: Grant Salisbury Elmquist 14H -C268 Battery
STATE OF
COLORADO
Fischbach - CDPHE, Ben <ben.fischbach@state.co.us>
COGA Priority Project: Grant Salisbury Elmquist 14H -C268 Battery
Sabrina Pryor <Sabrina.Pryor@crestonepr.com> Wed, Aug 5, 2020 at 9:07 AM
To: "Fischbach - CDPHE, Ben" <ben.fischbach@state.co.us>
Hello Ben,
Below are our responses to your questions. Please let me know if you have any additional questions:
• Pont 001 (Condensate Tanks): The sample was taken from the high side of the separator to effectively model the
buffer gas (point 014) and the tank emissions. There are not any sample analyses of pressurized liquids pulled
directly upstream of the oil storage tanks_
• Point 002 (Produced Water):
o The 2019 actual annual uncontrolled emissions were estimated at 3.90 tpy (using the APCD EF). With the
proposed site -specific emission factor uncontrolled emissions were estimated at 1,10 tpy. The intent was to
cancel the permit since the source is below 2 tpy, but I understand that the facility -wide emission exceed 2
tpy. Therefore can we modify the Produced Water permit with the reduced throughput, removal of control,
and revised emission factor and limit?
o We will accept this approach and agree with the increased factor to include'&B. Please redline the APEN
with the VOC EF 0.0695 Ib/bbl and a requested limit of 1.24 tpy.
• Point 014 (Buffer):
o The gas meter was installed on July 30th.
o The gas sample submitted was collected from the Grant Salisbury Elmquist Buffer House.
o 'Nth the Produced Water change, we will also need to modify the Buffer gas venting requested limit to 5.4
MMscf/yr and 7,61 tpy. This is necessary to keep the permitted facility emissions below 40 tpy VOC and
maintain weekly O&M monitoring. I have attached the updated form -102.
Thanks,
Sabrina M. Pryor
Air Quality Engineer
Crestone Peak Resources
10188 East 1-25 Frontage Road, Firestone, CO 80504
T: 303-774-3923
C: 303-242-1187
E: sabrina.pryor@crestonepr.com
CRESTONE PEAK
RISCURCE$
Please note Crestone Peak Resources is closed the 1St and 3rd Friday of each month.
[Quoted text hidden]
https://mail.google.com/mail/u/0?ik=0dd1 cdaf99&view=pt&search=all&permmsgid=msg-f%3A1674198450134616158&simpl=msg-f%3A16741984501... 1/2
9/30/2020 State.co.us Executive Branch Mail - COGA Priority Project: Grant Salisbury Elmquist 14H -C268 Battery
Form-102-GSE_14H-C268_FacilityWideEmissions_2020.08.pdf
157K
https://mail.google.com/mail/u/0?ik=0dd1 cdaf99&view=pt&search=all&permmsgid=msg-f%3A 1674198450134616158&simpl=msg-f%3A16741984501... 2/2
Hydrocarbon Liquid Loading APEN
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 15WE1415
AIRS ID Number: 123 / 9E30 / 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
Site Location:
Crestone Peak Resources Operating, LLC
Grant Salisbury Elmquist 14H -C268 Battery
Site Location
NENW, Section 14, T2N, R68W County: Weld
Mailing Address:
(Include Zip Code) 10188 East 1-25 Frontage Road
Firestone, CO 80504
NAICS or SIC Code: 1311
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.
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 07/2020
D A ',COLORO
1 I new.m,e R A D
H rb Fhv rm onvM
Page 5 of 29
Permit Number: 15WE1415
AIRS ID Number:
123 '9E30'003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑ 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 $353.13 must be
submitted along with the APEN filing fee.
-OR-
Q MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
❑✓ Change permit limit ❑ Transfer of ownership' 0 Other (describe below)
- OR
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info it Notes: Reduced annual throughput and updated to 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:
7/30/2015
For new ar reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
I2
•
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
0
Does this source load gasoline into transport vehicles?
Yes
No
•
D
Is this source located at an oil and gas exploration and production site?
Yes
No
p
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
O
■
Does this source splash fill less than 6,750 bbl of condensate per year?
Yes
No
p
■
Does this source submerge fill less than 16,308 bbl of condensate per year?
Yes
No
■
D
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020
:COLORADO
2 I I Department w Public
Hoeft 6 EnNronm.M
Page 6 of 29
Permit Number: 15WE1415
AIRS ID Number:
123 /9E30/003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: ❑✓ Condensate ❑ Crude Oil
0 Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
95,630
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this facility into: Tank Trucks
(e.g. "rail tank cars" or "tank trucks")
79,690
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature of
bulk liquid loading:
°F
True Vapor Pressure:
Psia @ 60 °F
Molecular weight of
displaced vapors:
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
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)
40.143677/ -104.974286
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
aerator
ck ID
rge Height Abov
Temp
Rate
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
0 Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 07/2020
3I
CC
COLORADO
. mt bE,,at c
HeaRIlS Enviranmer 1
Page 7 of 29
Permit Number: 15WE1415
AIRS ID Number:
123 /9E30/003
[Leave blank unless APCD has already assigned a permit a and AIRS ID]
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.
O Loading occurs using a vapor balance system:
Requested Control Efficiency:
❑ Combustion
Device:
Used for control of:
Rating:
Type:
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
VOCs, HAPs
NA
Enclosed Combustor
MMBtu/hr
Make/Model: NA
95
98
Minimum Temperature: NA °F Waste Gas Heat Content:
2,640 Btu/scf
Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 0.025 MMBtu/hr
❑ Other:
Pollutants Controlled:
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? ❑✓ Yes O No
If yes, describe the control equipment AND state the requested control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Overall Requested
Control Efficiency
(% reduction in emissions)
PM
SO,
NO,
CO
VOC
Enclosed Combustor (ECD)
95%
HAPs
Enclosed Combustor (ECD)
95%
Other:
❑✓ Using State Emission Factors (Required for GP07) VOC
❑✓ Condensate 0.236 Lbs/BBL
O Crude 0.104 Lbs/BBL
Benzene
0.00041 Lbs/BBL
0.00018 Lbs/BBL
n -Hexane
0.0036 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:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)s
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOX
NO,r
0.068
Ib/MMBtu
AP -42
--
3 05E-02
--
2.75E-02
CO
0.31
Ib/MMBtu
AP -42
--
0.14
--
0.13
VOC
"0.236
lb/bbl
APCD
9.13
0.46
11.28
0.56
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.
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 07/2020
iCOLORADO
4 I
Page 8 of 29
Permit Number: 15WE1415
AIRS ID Number:
123 /9E30/003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
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:
ChemicalName
Chemical
Abstract
-
Service ( CAS
Number �e
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
M etc.
Mfg-, )_jrbstyevr!
Uncontrolled
. Emissions
Controlled
Emissions6
(tbs/yeaj
Benzene
71432
000041
Ib/bbI
APCD
95.63
4.78
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.0036
lb/bbl
APCD
1,411
70.53
2,2,4-Trimethylpentane
540841
Other:
❑✓ Yes ❑ No
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.
08/27/2020
Signature of Legally Authorized Person (not a vendor or consultant) Date
Sabrina M. Pryor
Name (print)
Air Quality Engineer
Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General For more information or assistance call:
Permit registration fee of $353.13, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 07/2020
COLORADO
5I
=Ir,Environment
Page 9 of 29
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs wilt be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 2.0 e uAu
AIRS ID Number: 123 / 9E30 / m --
RECEIVED
JUN ' 1 2020
Gas Venting APEN - Form APCD-211 CDpHE
APCu
anc.i4P.S
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
Crestone Peak Resources Operating, LLC
Grant Salisbury Elmquist 14H -C268 Battery
NENW, Section 14, T2N, R68W
Mailing Address: 10188 East 1-25 Fronts a Road
(Include Zip code) 9
Firestone, CO 80504
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E Mail Address2:
Sabrina Pryor
(303) 774-3923
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 alt documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
ntirw A.
4215`2_
COLORADO
Page 19 of 82
Permit Number:
AIRS ID Number:
123 / 9E3o /
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name3 ❑ Add point to existing permit
O Change permit limit ❑ Transfer of ownership4 O Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info ft Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Buffer (separator) gas venting
controlled by enclosed combustor.
Company equipment Identification No. (optional): Buffer
For existing sources, operation began on:
For new, modified, or reconstructed sources, the projected start-up date is:
07/01/2020
Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Wilt this equipment be operated in any NAAQS
nonattainment area?
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
Section XVII.G?
APPtis i 12/2019
days/week weeks/year
✓❑ Yes
❑ Yes
❑ Yes
❑ No
0 No
El No
GOLORAOO
2 I .1Ei„.
Page 20 of 82
Permit Number:
AIRS ID Number: 123 / 9E30 /
Section 4 - Process Equipment Information
2 Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
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? 2 Yes
Gas Venting
Process Parameters5:
Liquid Throughput
Process Parameters5:
Vented Gas
Properties:
❑ No
Vent Gas
Heating Value:
1,998
BTU/SCF
Requested:
5.76
MMSCF/year
Actual:
__
MMSCF/year
-OR-
Requested:
bbl/year
Actual:
bbl/year
Molecular Weight:
35.16
VOC (Weight %)
60.75
Benzene (Weight %)
0.19
Toluene (Weight %)
0.19
Ethylbenzene (Weight %)
0.0089
Xylene (Weight %)
0.064
n -Hexane (Weight %)
1.62
2,2,4-Trimethylpentane (Weight %)
0.0009
Additional Required Documentation:
D Attach a representative gas analysis (including BTEX Ft n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Ft n -Hexane, temperature, and
pressure)
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
Fcim APC -21? Gas Venting A
3I
MPS
COLORADO
Page 21 of 82
Permit Number:
AIRS ID Number: 123 / 9E30 /
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.143677; -104.974286
❑✓ 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 ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
CO
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward
Horizontal O Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
O Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
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.
❑ VRU:
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: NA
Type: Enclosed Combustor
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: NA
MMBtu /hr
Make/Model: N/A
95
95
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating:
1,998
0.025
Btu/scf
MMBtu/hr
Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
" CD 1 Revision 12! 201
�{ ! :COLORADO
^t I NMIIiS wa�i
Page 22 of 82
Permit Number:
•
AIRS ID Number: 1 23 / 9E30 /
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 Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
PM
sox
NO,,
CO
VOC
Enclosed Combustor
100%
95%
HAPs
Enclosed Combustor
100%
95%
Other:
From what year is the following reported actual annual emissions data?
NA
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOx
NO„
0.068
Ib/MMBtu
AP -42
—
—
0.40
CO
0.31
Ib/MMBtu
AP -42
—
—
—
1.82
VOC
56,353
Ib/MMscf
Site specific
—
—
162
8.11
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 8 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
✓❑ Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(lbs/year)
Controlled
Emissions°
(lbs/year)
Benzene
71432
174
Ib/MMscf
Site specific
1,001
50.06
Toluene
108883
174
lb/MMscf
Site specific
1,302
50.08
Ethylbenzene
100414
8.23
lb/MMscf
Site specific
47.39
2,37
Xylene
1330207
59.57
lb/MMscf
Site specific
343
17.15
n -Hexane
110543
1.506
lb/MMscf
Site specific
8.671
434
2,2,4-Trimethylpentane
540841
0.83
Ib/MMscf
Site specific
4.76
0.24
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form4P i -2 = i
-Gas � -1 Ven-
r-F
12/2019
�► .coLORADO
5 I w.,.
Page 23 of 82
Permit Number:
AIRS ID Number: 123 /9E30/
PPC.C
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
/'
06/11/2020
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
❑� 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
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
Make check payable to: (303) 692-3150
Colorado Department of Public Health and Environment
Form 1P CGas Venting APEN Revis•Kn 12,2CI
6 I a®COLORADO
o��
Page 24 of 82
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