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Home My WebLink About20193676.tiffgo COLORADO Department of Public Health 8 Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 July 23, 2019 Dear Sir or Madam: RECEIVED WELD COUNTY COMMISSIONERS On July 25, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for HighPoint Operating Corporation - Fox Creek 33 Compressor Station. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, • Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pc (O1 c- Bedew cc:PLCTP), l—ILCJT) PwcJm/E.R/C+-i/cK,5 o'i iy / (1 2019-3676 a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Fox Creek 33 Compressor Station - Weld County Notice Period Begins: July 25, 2019 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: HighPoint Operating Corporation Facility: Fox Creek 33 Compressor Station Natural Gas Compressor Station NWNW Section 33, T12N, R63W Weld County The proposed project or activity is as follows: This project is a preconstruction application for a compression booster station located in Weld County outside of the 8 -hour nonattainment area (i.e. in the attainment area). This compressor station has requested permitting coverage for 3 -natural gas compression engines, one vapor recover unit (VRU) compressor driver engine, a single facility upset process flare, and a condensate tank battery (permitted under GP08 coverage). This facility, based on the emissions estimates and calculations provided, wilt be a synthetic minor facility for PSD and Title V programs for NOx, VOC and CO. 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): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • 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 19WE0223 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: COLORADO Department of Public Health 6 Environment Lauraleigh Lakocy Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 21 COLORADO Department of Public Health b Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Lauraleigh Lakocy Package it 394739 Received Date: 3/15/2019 Review Start Date: 4/23/2019 Section 01 - Facility Information Company Name: HighPoint Operating Corporation County AIRS ID: 123 Quadrant Section Township Range NWNW 33 12N Plant AIRS ID: A030 Facility Name: Physical Address/Location: County: Type of Facility: What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? I I Carbon Monoxide (CO) Fox Creek 33 Compressor Station NWNW quadrant of Section 33, Township 12N, Range 63W Weld County Natural Gas Compressor Station Section 02 - Emissions Units In Permit Application No Particulate Matter (PM) I I Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit P Issuance # Self Cert Required? Action Engineering Remarks . `.' Natural Gas RICE ENG-1 Yes 19WE0223 1 Yes Permit Initial Issuance Natural Gas RICE ENG-2 ' 19WE0223 1 Yes Permit Initial Issuance Natural Gas RICE ENG-3 r`t. s 19WE0223 Yes Permit Initial Issuance Natural Gas RICE ENG-4 'r e ; 19WE0223 _ Yes Permit Initial Issuance LCD_ Process Flare FL -1 -:i, 19WE0223 I. Yes Permit Initial Issuance Section 03 - Description of Project This project is a preconstruction application for a compression booster station located in Weld County outside of the 8 -hour nonattainment area (i.e. in the attainment area). This compressor station has requested permitting coverage for 3 -natural gas compression engines, one vapor recover unit (VRU) compressor driver engine, a single facility upset process flare, and a condensate tank battery (permitted under GP08 coverage). This facility, based on the emissions estimates and calculations provided, will be a synthetic minor facility for PSD and Title V programs for NOx, VOC and CO. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Yes Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants her€ SO2 SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes NOx CO NOx Li VOC PM2.5 PM10 TSP HAPs CO VOC PM2.5 PM10 TSP HAPs Summary of Preliminary Analysis - NG RICE Company Name HighPoint Operating Corporation Permit No. 19WE0223 Facility Name Fox Creek 33 Compressor Station AIRS 123/A030/002, 003, 0 Facility Location NWNW Sec 33 T12N R63W Review Date 04/23/2019 Facility Equipment ID ENG-1, ENG-2, ENG-3 Permit Engineer Lauraleigh Lakocy Requested Action New permit/newly Issuance No. 1 Emission Point Description One (1) Waukesha, Model L7044 GSI reciprocating internal combustion engine, selective catalytic reduction (NSCR) compression. Natural Gas Consumption reported Series 5, site rated system and emission Serial Number To Be Determined, natural gas -fired, turbo at 1900 horsepower. This engine shall be equipped air -fuel ratio control. This emission unit is used for natural Hours of Operation -charged, 4SRB with a non- gas Requested (mmscf/yr) 91.85 PTE Calculated at (hpy) 8760 Requested (mmscf/m) 7.80 Permit limits calculated at (hpy) 8760 Fuel Heat Value (btu/scf) 1362 BSCF (Btu/hp-hr) 7516 Emission Factor Sources Uncontrolled Controlled NOx Manufacturer Specifications Catalyst Specification Sheet VOC Manufacturer Specifications plus buffer No Control CO Manufacturer Specifications Catalyst Specification Sheet Formaldehyde Manufacturer Specifications Catalyst Specification Sheet SOx AP -42; Table 3.2-3 (7/2000); Natural Ga No Control TSP AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM 10 AP -42; Table 3.2-3 (7/2000); Natural Ga; No Control PM2.5 AP -42; Table 3.2-3 (7/2000); Natural Ga: No Control Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 219.2 9.2 219.2 95.8% VOC 12.8 12.8 12.8 0.0% CO 175.8 23.9 175.8 86.4% SOx 0.0 0.0 0.0 0.0% TSP 1.2 1.2 1.2 0.0% PM10 1.2 1.2 1.2 0.0% PM2.5 1.2 1.2 1.2 0.0% Total HAPs* 1.4 0.9 1.7 33.1% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (Ib/yr) HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 1835 734 1835 60.0% Methanol 383 383 383 0.0% Acetaldehyde 349 349 349 0.0% Acrolein 329 329 329 0.0% Benzene * 198 0.0% 1,3 -Butadiene * * 83 0.0% Toluene * * 70 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB over 500 HP located at a(n) Area Source Reg 7XVII.E Standards (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg 7 XVI.B (Ozone NM requirements) applies? No MACT 7777 (area Is this engine subject to MACT ZZ22 area source requirements? Yes source) NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes BSFC value came from the equipment specification sheet where the continuous engine power at 100% load is 1786 HP. Source is not going to have an initial compliance testing requirement for the engine; however, per the O & M plan, there will be regular portable analyzer testing required. Summary of Preliminary Analysis - NG RICE Company Name HighPoint Operating Corporation Facility Name Fox Creek 33 Compressor Station Facility Location NWNW Sec 33 T12N R63W Facility Equipment ID ENG-4 Requested Action New permit/newly reported emission Issuance No. 1 Permit No. AIRS Review Date Permit Engineer 19WE0223 0223 123/A030/005 04/23/2019 Lauraleigh Lakocy Emission Point Description One (1) Caterpillar, Model G3306B, Serial Number To Be Determined, natural gas -fired, naturally aspirated, 4SRB reciprocating intemal combustion engine, site rated at 133 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for natural gas compression. Natural Gas Consumption Requested (mmscf/yr) 8.20 Requested (mmscf/m) 0.70 Fuel Heat Value (btu/scf) 1362 BSCF (Btu/hp-hr) 8801 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) 8760 Permit limits calculated at (hpy) 8760 Uncontrolled Controlled NOx Manufacturer Specifications Manufacturer Specifications VOC Manufacturer Specifications No Control CO Manufacturer Specifications No Control Formaldehyde Manufacturer Specifications No Control SOx AP -42; Table 3.2-3 (7/2000); Natural Ga: No Control TSP AP -42; Table 3.2-3 (7/2000); Natural Ga: No Control PM10 AP -42; Table 3.2-3 (7/2000); Natural Ga; No Control PM2.5 AP -42; Table 3.2-3 (7/2000); Natural Ga; No Control Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency NOx 33.8 1.4 33.8 95.9% VOC 0.9 0.9 0.9 0.0% CO 2.8 2.8 2.8 0.0% SOx 0.0 0.0 0.0 0.0% TSP 0.1 0.1 0.1 0.0% PM10 0.1 0.1 0.1 0.0% PM2.5 0.1 0.1 0.1 0.0% Total HAPs* 0.0 0.0 0.5 0.0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Ha7arrinns Air PnlIntantc (1h/vr) .,,,,....,,,,,, cal), %AB I HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Control Efficiency Formaldehyde 951 951 951 0.0% Methanol * * 34 0.0% Acetaldehyde * * 31 0.0% Acrolein * * 29 0.0% Benzene * * 18 0.0% 1,3 -Butadiene * * 7 0.0% Toluene * * 6 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source is not required to model based on Division Guidelines Public Comment Public Comment Required MACT ZZZZ New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source Reg 7 XVII. E Standards (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg 7 X\A.B (Ozone NM requirements) applies? No MACT 7777 (area Is this engine subject to MACT ZZZZ area source requirements? Yes source) NSPS JJJJ Is this engine subject to NSPS JJJJ? Yes Note: JJJJ requriements are not currently included as permit conditions because the reg has not been adopted into Reg 6. Comments/Notes Engine is naturally aspirated so engine de -ration is permitted. Source is not going to have an initial compliance testing requirement for the engine; however, per the O & M plan, there will be regular portable analyzer testing required. Separator Venting Emissions Inventory 006 Separator Venting Facility AIRS ID: 123 County A030 Plant 006 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Backup Flare for up to 50 MMsd/year of natural gas Emission Control Device Description: Steffes Dual High Pressure High Capacity Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Natural Gas Vented Yes, meter will be installed within 180 days Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 0.0 MMscf per year 95 Requested Permit Limit Throughput = 50.0 MMscf per year Requested Monthly Throughput = 4 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 50 MMscf per year No Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description 1362 Btu/scf scf/bbl This back-up flare is used to flare the sales gas (compressor station gas) in the event of a field or facility process upset. The emission factors were developped using a sales gas sample from Critter Creek 15-2 2/5/2019, analyzed 2/11/2019. The sample was taken at 57 deg F with a sample pressure of 43 psig. The separator gas heating value was taken from this sample as well (gross dry real BTU/scf). MW 24.1011 lb/lb-mol Displacement Equation Ex=Q*MW `Xx/C Weight % Helium/Oxygen/Argon 0.01 CO2 5.27 N2 0.95 methane 46.49 ethane 13.97 propane 16.48 isobutane 2.19 n -butane 7.68 isopentane 1.81 n -pentane 2.34 cyclopentane 0.21 n -Hexane 0.57 cyclohexane 0.13 Other hexanes 1.05 heptanes 0.33 methylcyclohexane 0.11 224-TMP 0.00 Benzene 0.07 Toluene 0.05 Ethylbenzene 0.00 Xylenes 0.01 C8+ Heavies 0.26 Total 100.00 VOC Wt % 33.30 Emission Factors Separator Venting Emission Factor Source Pollutant Uncontrolled Controlled (Ih/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 21118.5714 1058.9286 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene 45.2770 2.2639 Toluene 29.8243 1.4912 Ethylbenzene 2.4801 0.1240 Xylene 7.3130 0.3656 n -Hexane 365.4592 18.2730 224 TMP 0.1272 0.0064 Primary Control Device Emission Factor Source Pollutant Uncontrolled Uncontrolled (Ib/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.000 Other - Explain PM2.5 0.000 Other - Explain Other - Explain AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) SOx 0.0248 33.805 NOx 0.0680 92.616 CO 0.3100 422.220 6 of 12 K:\PA\2019\19W E0223.CP 1 Separator Venting 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 (lbs/month) PM10 0.66 0.00 0.00 0.66 0.66 112 PM2.5 0.66 0.00 0.00 0.66 0.66 112 SOx 0.85 0.00 0.00 0.85 0.85 144 NOx 2.32 0.00 0.00 2.32 2.32 393 VOC 529.46 0.00 0.00 529.46 26.47 4497 CO 10.56 0.00 0.00 10.56 10.56 1793 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 2264 0 0 2264 113 Toluene 1491 0 0 1491 75 Ethylbenzene 124 0 0 124 6 Xylene 366 0 0 366 18 n -Hexane 18273 0 0 18273 914 224 TM P 6 0 0 6 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) 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 as 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 may be 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 90 tons per year? 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? No 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 and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 7 of 12 K:\PA\2019\19WE0223.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Emission factor for particulate matter came from AP -42, Chapter 13.5, Table 1, footnote d for "lightly smoking flare" - 40 ug/L. While this facility is subject to the requirements of Regulation 7, Section XVII, there are no control requirements for the back-up flare as it is not controlling a tank/separator/glycol dehy/etc. Therefore, this open flare is not subject to Regulation 7, Section XVII.B.2.e, contrary to the regulatory determination noted above. Because PS Memo 15-03 is based on the alternative emissions control requirements subject to XVII.B.2.e., the operating restrictions do not apply to this source. Monthly process limits are based on the requested emission limits from the APEN. The values differ slightly from those calcubted above. Initial testing is required as the emission factors were based off of an extended gas sample analysis Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 006 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/MMSCF PM2.5 0.00 0 lb/MMSCF SOx 33.80 0 lb/MMSCF NOx 92.62 0 Ib/MMSCF VOC 21178.57 95 lb/MMSCF CO 422.22 0 lb/MMSCF Benzene 45.28 95 lb/MMSCF Toluene 29.82 95 Ib/MMSCF Ethylbenzene 2.48 95 lb/MMSCF Xylene 7.31 95 lb/MMSCF n -Hexane 365.46 95 Ib/MMSCF 224 TMP 0.13 95 Ib/MMSCF 8 of 12 K:\PA\2019\19WE0223.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Source requires a permit Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes You have indicated that source is in the Attainment Area Colorado Regulation 7. Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? Yes Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The control device for this separator Is subject to Regulation 7, Section XVII.B.2.e Section XVII.B.2.e — Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend," 'may," "should, " and 'can, "is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and A,r Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Source Req Source is st rillEThe contro COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name 'HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID A030 Facility Name Fox Creek 33 Compressor Station History File Edit Date 5/14/2019 Ozone Status Attainment FMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 GP08 Condensate Tanks (3- 400 bbl) 39.4 0.1 5.9 0.0 Equip ID: CDNTK1-3, New emission 002 19WE0223 Waukesha 4SRB RICE, 1900 1.2 1.2 219.3 12.8 175.8 1.6 1.2 1.2 9.2 12.8 23.9 1.0 Equip ID: ENG-1, New emission source 003 19WE0223 Waukesha 4SRB RICE, 1900 1.2 1.2 219.3 12.8 175.8 1.6 1.2 1.2 9.2 12.8 23.9 1.0 Equip ID: ENG-2, New emission source 004 19WE0223 Waukesha 4SRB RICE, 1900 1.2 1.2 219.3 12.8 175.8 1.6 1.2 1.2 9.2 12.8 23.9 1.0 Equip ID: ENG-3, New emission source 005 19WE0223 Caterpillar G3306B 145 HP 0.1 0.1 33.8 0.9 2.8 0.5 0.1 0.1 1.4 0.9 2.8 0.5 Equip ID: ENG-4, New emission source 006 19WE0223 Backup Flare 0.7 0.7 0.9 2.3 529.6 10.6 11.3 0.7 0.9 0.9 2.3 26.5 10.6 0.6 New emission source 0.0 0.0 APEN Exempt/lnsignificants 0.0 0.0 Produced Water Tank 0.1 0.0 0.0 0.0 From Form APCD-102 rec'd 3/15/2019 Natural Gas Fired Process Heaters 0.6 0.5 0.0 0.6 0.5 0.0 From Form APCD-102 rec'd 3/15/2019 Fugitive Equipment Leaks 0.2 0.0 0.2 0.0 From Form APCD-102 rec'd 3/15/2019 Truck Loading 0.80 0.0 0.3 0.0 From Form APCD-102 rec'd 3/15/2019 FACILITY TOTAL 4.4 4.4 0.0 0.9 694.6 609.2 0.2 541.3 16.8 4.4 4.6 0.0 0.9 31.9 71.7 0.5 85.6 4.3 VOC: NOx: CO: HAPS: Syn Syn Syn True Minor Minor Minor (PSD Minor (PSD (PSD and OP) and OP) and OP) Permitted Facility Total 4.4 4.4 0.0 0.9 694.0 608.4 0.0 540.8 16.7 4.4 4.6 0.01 0.9 _ 31.3 71.7 0.0 85.1 4.2 Excludes units exempt from (A) Change in Permitted Emissions 4.4 4.6 0.0 0.9 31.3 71.7 0.0 , 85.1 Pubcom minor limits not required required & project based because of synthetic emissions. Modeling on division guidelines. Note 1 Total VOC Faci ity Emissions (point and fugitive 72.2 Facility is eligible for GP02 because < 90 ;A) Change in Total Permitted VOC emissions (point and fugitive 71.7 Project emissions not ublic comment required less than 50 tpy - Note 2 Page 10 of 12 Printed 5/14/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name HighPoint Operating Corporation 123 A030 Fox Creek 33 Compressor Station Emissions - uncontrolled (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tPY) IPreviousFAC1L1TY1TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 GP08 Condensate Tanks (3- 400 bbl) 18 12 1 4 240 0 0.1 002 19WE0223 Waukesha 4SRB RICE, 1900 HP 1835 349 329 198 70 3 24 383 1.6 003 19WE0223 Waukesha 4SRB RICE, 1900 HP 1835 349 329 198 70 3 24 383 1.6 004 19WE0223 Waukesha 4SRB RICE. 1900 HP 1835 349 329 198 70 3 24 383 1.6 005 19WE0223 Caterpillar G3306B 145 HP 4SRB 952 31 29 18 6 0 2 . 34 0.5 006 19WE0223 Backup Flare 2264 1492 124 350 18277 6 11.3 0.0 APEN Exempt/Insignificants 1 0.0 Produced Water Tank 1 3 0.0 Natural Gas Fired Process Heater; 1 23 0.0 Fugitive Equipment Leaks 1 2 0 1 9 0 0.0 Truck Loading 2 1 0 0 33 0 0.0 TOTAL (tpy) 3.2 0.5 0.5 1.4 0.9 0.1 0.2 9.3 0.6 0.0 0.0 0.0 16.8 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (lbs per year) POIN PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane TOTAL (tPY) McOH 224 TMP H2S IeviousFAC1L1TYTOTAL 0 0 0 0 0 0 0 0 0.0 0 0 0 0 001 GP08 Condensate Tanks (3- 400 bbl) 1 1 1 0 0 12 0.0 002 19WE0223 Waukesha 4SRB RICE, 1900 HP 734 349 329 198 70 3 24 1.0 383 003 19WE0223 Waukesha 4SRB RICE. 1900 HP 734 349 329 198 70 3 24 383 1.0 004 19WE0223 Waukesha 4SRB RICE; 1900 HP 734 349 329 198 70 3 24 1.0 383 11 19WE0223.CP1 5/14/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name County AIRS ID Plant AIRS ID Facility Name HighPoint Operating Corporation 123 A030 Fox Creek 33 Compressor Station 005 19WE0223 Caterpillar G3306B 145 HP 4SRB 952 31 29 18 6 0 2 34 0.5 006 19WE0223 Backup Flare 113 75 6 17 914 0 0.6 0.0 APEN Exempt/Insignificants 0.0 Produced Water Tank 0 0 0.0 Natural Gas Fired Process Heater: 1 72 0.0 Fugitive Equipment Leaks 1 2 0 1 9 0 0.0 Truck Loading 1 0 0 0 11 0 0.0 TOTAL (tpy) 1.6 0.5 0.5 0.4 0.1 0.0 0.0 0.5 0.6 0.0 0.0 0.0 4.3 12 19WE0223.CP1 5/14/2019 STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 19WE0223 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 HighPoint Operating Corporation Fox Creek 33 Compressor Station 123/A030 NWNW SEC 33 T12N R63W Weld County Natural Gas Compressor Station THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description ENG-1 002 One (1) Waukesha, Model L7044 GSI Series 5, Serial Number To Be Determined, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion engine, site -rated at 1,786 horsepower. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control ENG-2 003 One (1) Waukesha, Model L7044 GSI Series 5, Serial Number To Be Determined, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion engine, site -rated at 1,786 horsepower. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control ENG-3 004 One (1) Waukesha, Model L7044 GSI Series 5, Serial Number To Be Determined, natural gas -fired, turbo- charged, 4SRB reciprocating internal combustion engine, site -rated at 1,786 horsepower. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control AIRS ID: 123/A030 Page 1 of 18 NGEngine Version 2014-1 Colorado Department of Public Health and Environment Air Pollution Control Division ENG-4 005 One (1) Caterpillar, Model G3306B, Serial Number To Be Determined, natural gas -fired, naturally aspirated, 4SRB reciprocating internal combustion engine, site -rated at 133 horsepower. This emission unit is used for natural gas compression. Non -selective catalytic reduction (NSCR) system and air -fuel ratio control FL -1 006 Venting of Natural Gas due to Process Upset Open Flare Points 002, 003, 004: These engines may each be replaced with another engine in accordance with the temporary engine replacement provision or with another Waukesha L7044 GSI Series 5 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. Point 005: This engine may each be replaced with another engine in accordance with the temporary engine replacement provision or with another Caterpillar G3306 engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. 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 THOSE 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 (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section 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 shall 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. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) F.4. ) AIRS ID: 123/A030 Page 2 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 4. The operator shall 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. (Reference: Regulation No. 3, Part B, Section III.E.) 5. Points 002, 003, 004, 005: The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 6. Point 006: The operator shall install a flow meter to monitor and record volumetric flow rate of natural gas vented by the back-up flare prior to facility start-up. 7. The operator shall 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 8. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Monthly Limits: Facility Equipment ID AIRS Point Pounds per Month Emission Type pM2.5 NOX VOC CO ENG-1 002 --- 1,558 2,182 4,051 Point ENG-2 003 --- 1,558 2,182 4,051 Point ENG-3 004 --- 1,558 2,182 4,051 Point ENG-4 005 --- 238 159 475 Point (Note: Monthly limits are based on a 31 -day month.) The owner or operator shall calculate monthly emissions based on the calendar month. AIRS ID: 123/A030 Page 3 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO ENG-1 002 9.2 12.8 23.9 Point ENG-2 003 --- 9.2 12.8 23.9 Point ENG-3 004 9.2 12.8 23.9 Point ENG-4 005 - 1.4 2.8 Point FL -1 006 --- 2.3 26.5 10.6 Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. During the first twelve (12) months of operation, compliance with both the monthly and annual emission limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an Air Pollutant Emission Notice (APEN), at this facility. 9. 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 APEN and receive a modified permit prior to the use of any other method of calculating emissions. 10. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled ENG-1 002 Non -selective catalytic reduction system and air/fuel ratio controller NOx, CO, HCHO ENG-2 003 Non -selective catalytic reduction system and air/fuel ratio controller NOx, CO, HCHO ENG-3 004 Non -selective catalytic reduction system and air/fuel ratio controller NOx, CO, HCHO ENG-4 005 Non -selective catalytic reduction system and air/fuel ratio controller NOx FL 1 006 Natural Gas is routed to an open flare during a process upset VOC, HAPs AIRS ID: 123/A030 Page 4 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division PROCESS LIMITATIONS AND RECORDS 11. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Monthly Limit (31 days) ENG-1 002 Consumption of natural gas as a fuel 91.8 MMscf/yr 7.80 MMscf/month ENG-2 003 Consumption of natural gas as a fuel 91.8 MMscf/yr 7.80 MMscf/month month ENG-3 004 Consumption of natural gas as a fuel 91.8 MMscf/yr 7.80 MMscf/month ENG-4 005 Consumption of natural gas as a fuel 8.20 MMscf/yr 0.70 MMscf/month FL -1 006 Natural Gas Venting 50 MMscf/yr ---* *Note: Point 006 does not have monthly process/consumption limits Points 002, 003, 004, 005: Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facility -wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall 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 shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 12. The owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall 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 13. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) 14. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) AIRS ID: 123/A030 Page 5 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 15. Points 002, 003, 004, 005: 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. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. Et 4.) 16. Points 002, 003, 004, 005: This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥500HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. 17. Point 006: No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) OPERATING Ft MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator shall 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 your OEM plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 19. Point 006: The owner/operator shall complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpentane content (weight fraction) of this AIRS ID: 123/A030 Page 6 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division emission stream. Results of the Analysis shall be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 20. Point 006: The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 9, 40 C.F.R. Part 60, Appendix A, to measure opacity from the flare for one continuous hour. (Regulation Number 1, Section II.A.5) Periodic Testing Requirements 21. Points 002, 003, 004: These engines are subject to the periodic testing requirements as specified in the OaM plan as approved by the Division. Revisions to your OEtM plan are subject to Division approval. Replacements of these units completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. 22. Point 005: This engine is subject to the periodic testing requirements as specified in the OEtM plan as approved by the Division. Revisions to your OEtM plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment B. ADDITIONAL REQUIREMENTS 23. A revised APEN shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or AIRS ID: 123/A030 Page 7 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A and/or Attachment B. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 24. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). 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 Division as provided in AQCC Regulation No. 3, Part B, Section II.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 Division in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the Divisionas 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 Division 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 shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Division on grounds set forth in the Colorado Air Quality Control Act and regulations AIRS ID: 123/A030 Page 8 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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. 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: Lauraleigh Lakocy Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation AIRS ID: 123/A030 Page 9 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 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 shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 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 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 shall 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. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Controlled Emission Rate (lb/yr) ENG-1 002 Formaldehyde 50000 1,835 734 Methanol 67561 383 383 Acetaldehyde 75070 349 349 Acrolein 107028 329 329 Benzene 71432 198 198 1,3 -Butadiene 106990 83 83 Toluene 108883 70 70 ENG-2 003 Formaldehyde 50000 1,835 734 Methanol 67561 383 383 Acetaldehyde 75070 349 349 Acrolein 107028 329 329 Benzene 71432 198 198 1,3 -Butadiene 106990 83 83 Toluene 108883 70 70 ENG-3 004 Formaldehyde 50000 1,835 734 Methanol 67561 383 383 Acetaldehyde 75070 349 349 Acrolein 107028 329 329 AIRS ID: 123/A030 Page 10 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Benzene 71432 198 198 1,3 -Butadiene 106990 83 83 Toluene 108883 70 70 ENG-4 005 Formaldehyde 50000 951 951 Methanol 67561 34 34 Acetaldehyde 75070 31 31 Acrolein 107028 29 29 Benzene 71432 18 18 FL -1 006 Benzene 71432 2,264 113 Toluene 108883 1,492 75 Xylenes 1330207 350 18 n -Hexane 110543 18,277 914 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 002, 003, 004: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 3.5052 11.95 0.1467 0.50 CO 2.8100 9.58 0.3813 1.30 VOC 0.2053 0.70 0.2053 0.70 50000 Formaldehyde 0.0147 0.05 0.0059 0.02 67561 Methanol 0.0031 0.01 0.0031 0.01 75070 Acetaldehyde 0.0028 0.01 0.0028 0.01 107028 Acrolein 0.0026 0.01 0.0026 0.01 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7,516 Btu/hp-hr, a maximum designed horsepower value of 1,900 HP, and a fuel heat value of 1,362 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EF Source Controlled EF Source NOx Manufacturer Specifications Catalyst Specification Sheet CO Manufacturer Specifications Catalyst Specification Sheet VOC Manufacturer Specifications plus buffer No Control 50000 Formaldehyde Manufacturer Specifications Catalyst Specification Sheet 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas No Control AIRS ID: 123/A030 Page 11 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division Point 005: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Factors lb/MMBtu - Controlled g/bhp-hr NOx 6.0470 24.14 0.2505 1.00 CO 0.5010 2.00 0.5010 2.00 VOC 0.1678 0.67 0.1678 0.67 50000 Formaldehyde 0.0852 0.34 0.0852 0.34 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 8801 Btu/hp-hr, a maximum designed horsepower value of 145, and a fuel heat value of 1362 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx Manufacturer Specifications Manufacturer Specifications CO Manufacturer Specifications No Control VOC Manufacturer Specifications No Control 50000 Formaldehyde Manufacturer Specifications No Control Point 006: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 92.8 92.8 AP -42, Chapter 13.5 CO 422.4 422.4 VOC 21,183 1,059.15 Representative Extended Gas Analysis 71432 Benzene 45.3 2.265 108883 Toluene 29.8 1.49 1330207 Xylene 7.0 0.35 110543 n -Hexane 365.5 18.275 Note: The controlled emissions factors for this point are based on the open flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall 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) Points 002, 003, 004, 005: This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting - effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf 8) Points 002, 003, 004, 005: This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January 18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008 amendments to include requirements for area sources and engines < 500 hp located at major sources have not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 8. A copy of the complete subpart is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf Additional information regarding area source standards can be found on the EPA website at: http://www.epa.gov/ttn/atw/area/arearules.html AIRS ID: 123/A030 Page 12 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, CO PSD Synthetic Minor Source of: NOx, VOC, CO MACT ZZZZ Area Source Requirements: Applicable 10) 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 KKKK 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 11) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/A030 Page 13 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division ATTACHMENT A: ALTERNATIVE OPERATING SCENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/A030 Page 14 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division 2.1.2 The owner or operator may permanently replace the existing engine with another engine with the same manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement engine complies with all permit limitations and other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.gov/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: www.colorado.gov/cdphe/portable-analyzer-monitoring-protocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement AIRS ID: 123/A030 Page 15 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division engine will be subject to, the results of the test shall be converted to the appropriate units as described in the above -mentioned Portable Analyzer Monitoring Protocol document. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3 Applicable Regulations for Permanent Engine Replacements 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B 5 II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or S02 exceeds 40 tons/yr. ' For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. AIRS ID: 123/A030 Page 16 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. Emission Standards: Section XVII. E - State -only requirements Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC January 1, 2008 2.0 4.0 1.0 100<Hp<500 January 1, 2011 1.0 2.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1 /2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8 (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports AIRS ID: 123/A030 Page 17 of 18 Colorado Department of Public Health and Environment Air Pollution Control Division required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. 2.4 Additional Sources The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS- approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/A030 Page 18 of 18 Spark Ignition Engine APEN Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit REcErvED BAR i 5 7piy All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.00v/cdphe/apcd. 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: (Cllk1E oza3 AIRS ID Number: 123 /A Fo / o©2, [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Fox Creek 33 Compressor Station Site Location: NWNW Section 33, T12N, R63W Mailing Address: (Include Zip Code) 1099 18th Street, Suite 2300 Portable Source Home Base: Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.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. 3`i417.34 COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 Permit Number: AIRS ID Number: 1 23 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) ✓❑ STATIONARY source 0 PORTABLE source p Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,875 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name4 ❑ Add point to existing permit O Change permit limit 0 Transfer of ownerships 0 Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacement6 Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 5 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? Yes If yes, provide the Company Equipment Identification No. ENG-1 General description of equipment and purpose: Waukesha L7044GSI Series 5 engine used for gas lift compression. For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http: / /www.colorado. gov/cdphe/attainment) 10/1/2019 ❑ Yes ❑✓ No Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 June -Aug: 25 Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 weeks/year Sept -Nov: 25 [COLORADO Permit Number: AIRS ID Number: 1 23 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) 0 Compression ❑ Pump Jack ❑ Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Waukesha Engine Model: L7044 GSI Series 5 Serial Number: TBD hours/year What is the maximum designed horsepower rating? 1,900 hp What is the maximum manufacturer's site -rating? 1,786 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,516 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑ Lean Burn ✓❑ Rich Burn Aspiration: ❑ Natural ❑✓ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑✓ Yes ❑ No If yes, what type of AFRC is in use? ❑✓ 02 Sensor (mV) ❑NOx Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOx design? ❑ Yes ✓❑ No Engine Dates: What is the manufactured date of this engine? 2019 What date was this engine ordered? 2019 What is the date this engine was first located to Colorado? TBD What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? TBD What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes ❑✓ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 COLORADO 3 Permit Number: AIRS ID Number: 1 23 I [Leave blank unless APCD has already assigned a permit /: and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.972465 / -104.446975 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) ENG-1 25 1132 8265 129 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): Interior stack diameter (inches): 14 ❑ Upward with obstructing raincap Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate ® 100% Load (SCFI hour) Actual Annual Fuel Use (MMSCFI year) = Requested Annual Permit Limits (MMSCFI year) 10,485 91.8 91.8 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) ❑✓ Field Natural Gas Heating value: 1,362 BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf D Other (describe): Heating Value (give units): s Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 If fuel. heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4I AV COLORADO Permit Number: MRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) Not Applicable 0 PM 10 Not Applicable 0 PM 2.5 Not Applicable 0 SOX Not Applicable 0 NOx NSCR/AFRC 95.8 VOC Not Applicable 0 CO NSCR/AFRC 86 Other: NSCR/AFRO 60 [Formaldehyde] Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor = Actual Annual Emissions i0 Requested Annual Permit--_ B Emission Limit(s) Uncontrolled Basis Units Source (AP -42, Mfg.. etc) Uncontrolled Emissions i (tons/year) Controlled Emissions (tons/year) - Uncontrolled Emissions (tons/year) - Controlled Emissions --(tons/year) TSP (PM) 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 PM 10 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 PM2.5 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 SOX 0.00059 lb/MMBtu AP -42, Table 3.2-3 0.04 0.04 NOX 11.95 g/hp-hr Mfg. /Reg 7 Table 1 219.25 9.17 VOC 0.70 g/hp-hr Mfg. /Reg 7 Table 1 12.84 12.84 CO 9.58 g/hp-hr Mfg. /Reg 7 Table 1 175.76 23.85 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 ❑ Yes ❑ No lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions10 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Formaldehyde 50000 0.05 g/hp-hr Mfg. Acetaldehyde 75070 0.00279 lb/MMBtu AP -42, Table 3.2-3 Acrolein 107028 0.00263 lb/MMBtu AP -42, Table 3.2-3 Benzene 71432 0.00158 lb/MMBtu AP -42, Table 3.2-3 Other: 67-56-1 0.00306 lb/MMBtu AP -42, Table 3.2-3 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5I COLORADO pew-arr,v N Pebvc Vies„ry S Esv:;e:a�av+l Permit Number: AIRS ID Number: 123 I i [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. .Nf Signature of Legally Authori. -d Person (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (please 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 $1,875, 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 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 ®CCIOfi ADO MAR 1 5 2019 Spark Ignition Engine APEN Form APCD-201 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd, 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. C� Jf nFiry Permit Number: f?v.1EO2i3 AIRS ID Number: 123 /Ao3p [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: HighPoint Operating Corporation Fox Creek 33 Compressor Station Site Location: NWNW Section 33, T12N, R63W Mailing Address: (Include Zip Code) 1099 18th Street, Suite 2300 Portable Source Home Base: Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 354733 ©© OLOP. ADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 Permit Number: AIRS ID Number: 1 23 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source O PORTABLE source 0 Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,875 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name4 ❑ Add point to existing permit O Change permit limit O Transfer of ownerships O Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit-exempt/grandfathered source O Notification of Alternate Operating Scenario (AOS) permanent replacement6 Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 5 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? Yes If yes, provide the Company Equipment Identification No. ENG-2 General description of equipment and purpose: Waukesha L7044GSI Series 5 engine used for gas lift compression. For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http: / /www.colorado. oov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 10/1/2019 ❑ Yes ❑✓ No Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 AVlcoLORkoo Permit Number: AIRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑✓ Compression ❑ Pump Jack ❑ Water Pump 0 Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Waukesha Engine Modet: L7044 GSI Series 5 Serial Number7: TBD hours/year What is the maximum designed horsepower rating? 1,900 hp What is the maximum manufacturer's site -rating? 1,786 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,516 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke p 4 -Stroke Combustion: ❑ Lean Burn ✓❑ Rich Burn Aspiration: ❑ Natural ❑✓ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ✓❑ Yes ❑ No If yes, what type of AFRC is in use? ✓❑ 02 Sensor (mV) ONOx Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOx design? ❑ Yes ❑✓ No Engine Dates: What is the manufactured date of this engine? 2019 What date was this engine ordered? 2019 What is the date this engine was first located to Colorado? TBD What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? TBD What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes ❑✓ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 I !COLORADO Permit Number: AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.972465 / -104.446879 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (`F) Flow Rate (ACFM) Velocity (ft/sec) ENG-2 25 1132 8265 129 Indicate the direction of the Stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) p Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): 14 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100% Load (SCF/ hour) Actual Annual Fuel Use (MMSCF/ year) Requested Annual Permit Limit8 (MMSCF/ year) 10,485 91.8 91.8 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) 0 Field Natural Gas Heating value: 1,362 BTU/scf ❑ Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf El Other (describe): Heating Value (give units): 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. [COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I Permit Number: AIRS ID Number: 1 23 I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) Not Applicable 0 PM 1 ° Not Applicable 0 PM 2.5 Not Applicable 0 SOx Not Applicable 0 NOx NSCR/AFRC 95.8 VOC Not Applicable 0 CO NSCR/AFRC 86 Other: NSCR/AFRC 60 [Formaldehyde] Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions10 Requested Annual Permit Emission Limit(s)8 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (tonslyear) Controlled - Emissions -(tons/year)- _ Uncontrolled_ Emissions (tons/year) - Controlled Emissions (tons/year) TSP (PM) 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 PM 10 0.019 lb/MMBtu AP -42, Table 3.2-3 1,21 1.21 PM 2.5 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 SOx 0.00059 lb/MMBtu AP -42, Table 3.2-3 0.04 0.04 NOx 11.95 g/hp-hr Mfg. /Reg 7 Table 1 219.25 9.17 VOC 0.70 g/hp-hr Mfg. /Reg 7 Table 1 12.84 12.84 CO 9.58 g/hp-hr Mfg. /Reg 7 Table 1 175.76 23.85 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 ❑ Yes ❑ No lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS (CAS) Number Emission Factor Actual Annual Emissions10 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Formaldehyde 50000 0.05 g/hp-hr Mfg. Acetaldehyde 75070 0.00279 lb/MMBtu AP -42, Table 32-3 Acrolein 107028 0.00263 lb/MMBtu AP -42, Table 3.2-3 Benzene 71432 0.00158 lb/MM Btu AP -42, Table 3.2-3 Other: 67-56-1 0.00306 lb/MMBtu AP -42, Table 3.2-3 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5I (COLORADO Permit Number: AIRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. Signature of Legally Authorize Person (not a vendor or consultant) Marsha Sonderfan —16) Date Date EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance Ej 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 $1,875, 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 Or visit the APCD website at: https: / /www.colorado. goy /cd phe / apcd COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 Spark Ignition Engine APEN Form APCD-201 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. 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: i q 1E223 *f p ' 5 ni9 Alree AIRS ID Number: 123 /Am /664i [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Fox Creek 33 Compressor Station Site Location: NWNW Section 33, T12N, R63W Mailing Address: (Include Zip Code) 1099 18th Street, Suite 2300 Portable Source Home Base: Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.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-201 - Spark Ignition Engine APEN - Revision 7/2018 354734 �j ,COLORADO Amn•,=„ Permit Number: AIRS ID Number: 1 23 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source O PORTABLE source O Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,875 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name' O Add point to existing permit O Change permit limit O Transfer of ownerships ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit-exempt/grandfathered source O Notification of Alternate Operating Scenario (AOS) permanent replacement6 Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 5 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 6 This does not apply to General Permit GPO2, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? If yes, provide the Company Equipment Identification No. General description of equipment and purpose: gas lift compression. ENG-3 Yes Waukesha L7044GSI Series 5 engine used for For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 10/1/2019 ❑ Yes E No Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 BICOLOR ADO 2 I AV Permit Number: AIRS ID Number: 123 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑✓ Compression ❑ Pump Jack ❑ Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? 0 Engine Make: Waukesha Engine Mode{: L7044 GSI Series 5 Serial Number: TBD hours/year What is the maximum designed horsepower rating? 1,900 hp What is the maximum manufacturer's site -rating? 1,786 hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,516 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke ✓❑ 4 -Stroke Combustion: ❑ Lean Burn ❑✓ Rich Burn Aspiration: ❑ Natural ❑✓ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ✓❑ Yes D No If yes, what type of AFRC is in use? ❑✓ OZ Sensor (mV) ENOx Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOx design? ❑ Yes 0 No Engine Dates: What is the manufactured date of this engine? 2019 What date was this engine ordered? 2019 What is the date this engine was first located to Colorado? TBD What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? TBD What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 1 V'COLORADO coon ri '1e1. Permit Number: AIRS ID Number: 123 / [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.972465 / -104.446783 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (SF) Flow Rate (ACFM) Velocity (ft/sec) ENG-3 25 1132 8265 129 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle El Other (describe): Interior stack diameter (inches): 14 ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate ® 100% Load (SCFI hour) Actual Annual Fuel Use (MMSCFI year) Requested Annual Permit Limits (MMSCF/ year) 10,485 91.8 91.8 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) 0 Field Natural Gas Heating value: 1,362 BTU/scf El Propane (assumed fuel heating value of 2,300 BTU/scf) ❑ Landfill Gas Heating Value: BTU/scf ❑ Other (describe): Heating Value (give units): 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 If fuel heating value is different than the listed assumed value, provide this information in the "other" field. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 (COLORADO 4 I �cin,, Permit Number: AIRS ID Number: 1 23 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? E Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) Not Applicable 0 PM10 Not Applicable 0 PM 2.5 Not Applicable 0 SOx Not Applicable 0 NOx NSCR/AFRC 95.8 VOC Not Applicable 0 CO NSCR/AFRC 86 Other: NSCR/AFRC 60 [Formaldehyde[ Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor io Actual Annual Emissions1°- Requested Annual Permit Emission Limit(s)8 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (tons/year) Controlled . Emissions - (tons/year)- Uncontrolled Emissions- ---(tons/year) -- Controlled Emissions --- (tons/year) TSP (PM) 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 PM10 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 PM 2.5 0.019 lb/MMBtu AP -42, Table 3.2-3 1.21 1.21 SOx 0.00059 lb/MMBtu AP -42, Table 3.2-3 0.04 0.04 NOx 11.95 g/hp-hr Mfg. /Reg 7 Table 1 219.25 9.17 VOC 0.70 g/hp-hr Mfg. /Reg 7 Table 1 12.84 12.84 CO 9.58 g/hp-hr Mfg. /Reg 7 Table 1 175.76 23.85 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 ❑ Yes ❑ No lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions10 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Formaldehyde 50000 0.05 g/hp-hr Mfg. Acetaldehyde 75070 0.00279 lb/MMBtu AP -42, Table 3.2-3 Acrolein 107028 0.00263 lb/MMBtu AP -42, Table 3.2-3 Benzene 71432 0.00158 lb/MMBtu AP -42, Table 3.2-3 Other: 67-56-1 0.00306 lb/MMBtu AP -42, Table 3.2-3 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 51 ,COLORADO Permit Number: AIRS ID Number: 123 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. kA/l%`'6vt,0-,_ 1 - Signature of Legally Authorized Jerson (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance ✓l 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 $1,875, 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.g,ov/cdphe/apcd Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 Ay iCOLORADO 6 I , C nt Fvb:¢ Nsa�il . ^+.l AMR 1 5 2019 Spark Ignition Engine APEN Form APCD-201 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.00v/cdphe/apcd. 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. A?Qcp on an, Permit Number: /iwE 23 AIRS ID Number: 123 /A -0,3/06.5 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Namei: Site Name: HighPoint Operating Corporation Fox Creek 33 Compressor Station Site Location: NWNW Section 33, TI 2N, R63W Mailing Address: (Include Zip Code) 1099 18th Street, Suite 2300 Portable Source Home Base: Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 394735 Icc LO RADo Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source (check one below) O STATIONARY source ❑ PORTABLE source O Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,875 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name' ❑ Add point to existing permit O Change permit limit 0 Transfer of ownerships ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit-exempt/grandfathered source ❑ Notification of Alternate Operating Scenario (AOS) permanent replacement° Additional Info Et Notes: 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) must be submitted. 5 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? If yes, provide the Company Equipment Identification No. ENG-4 Yes General description of equipment and purpose: Caterpillar G3306B engine used for VRU compression. For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http: //www.colorado.gov/cdohe /attainment) Normal Hours of Source Operation: 24 hours/day 7 10/1/2019 ❑ Yes 0 No Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 ,COLORADO 2 `,,,m Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ['Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑✓ Compression ❑ Pump Jack ❑ Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? Engine Make: Caterpillar Engine Model: G33O6B What is the maximum designed horsepower rating? 145 hp What is the maximum manufacturer's site -rating? 133 hp 0 Serial Number: TBD kW hours/year What is the engine Brake Specific Fuel Consumption at 100% Load? 8,801 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke 4 -Stroke Combustion: ❑ Lean Burn ✓❑ Rich Burn Aspiration: ❑✓ Natural ❑ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 2 Yes ❑ No If yes, what type of AFRC is in use? ❑ O2 Sensor (mV) ❑NOX Sensor (ppm) ❑✓ Other: Is this engine equipped with a Low-NOx design? ❑ Yes ✓❑ No Engine Dates: What is the manufactured date of this engine? 2019 What date was this engine ordered? 2019 What is the date this engine was first located to Colorado? 2019 What is the date this engine was first placed in service/operation? TBD What is the date this engine commenced construction? TBD What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? ❑ Yes ❑✓ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 !COLORAD0 I°.�w,Mor.rw4 Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.972600 / -104.446367 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. ('F) Flow Rate (ACFM) Velocity (ft/sec) ENG-4 10 1,136 652 125 Indicate the direction of the Stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Square/Rectangle ❑ Other (describe): Interior stack diameter (inches): Interior stack diameter (inches): 4 ❑ Upward with obstructing raincap Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100% Load (SCF/hour) Actual Annual Fuel Use (MMSCF/year) Requested Annual Permit Limits (MMSCF/ year) 937 8.2 8.2 From what year is the actual annual amount? 2019 Indicate the type of fuel used9: ❑ Pipeline Natural Gas ❑✓ Field Natural Gas ❑ Propane ❑ Landfill Gas ❑ Other (describe): (assumed fuel heating value of 1,020 BTU/scf) Heating value: 1,362 BTU/scf (assumed fuel heating value of 2,300 BTU/scf) Heating Value: BTU/scf Heating Value (give units): 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 VcOIO RADA Permit Number: AIRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) Not Applicable o PM 10 Not Applicable 0 PM2.5 Not Applicable 0 SOx Not Applicable 0 NOX NSCR/AFRC 96 VOC Not Applicable 0 CO Not Applicable 0 Other: Not Applicable 0 Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor �o Actual Annual Emissionsl° __ Requested Annual Permit _ Emission Limit(s)8 Uncontrolled Basis Units (AP -42, Mfg.- etc)- Uncontrolled Emissions (tons/year) Controlled - Emissions (tons/year)- Uncontrolled Emissions (tons/year) - Controlled _ Emissions - (tons/year) TSP (PM) 0.019 lb/MMBtu AP -42, Table 3.2-3 0.11 0.11 PM 10 0.019 lb/MMBtu AP -42, Table 3.2-3 0.11 0.11 PM2.5 0.019 lb/MMBtu AP -42, Table 3.2-3 0.11 0.11 SOx 0.00059 lb/MMBtu AP -42, Table 3.2-3 0.003 0.003 NOx 24.14 g/hp-hr Mfg. /Reg 7 Table 1 33.80 1.40 VOC -441.,.39 t0. (bi g/hp-hr Mfg. /Reg 7 Table 1 94e e..9 x.46- c,.cl CO 2.0 gThp-hr Mfg. /Reg 7 Table 1 2.80 2.80 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 ❑ Yes ❑ No lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions10 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Formaldehyde 50000 0.34 g/hp-hr Mfg. Acetaldehyde 75070 0.00279 lb/MMBtu AP -42, Table 3.2-3 Acrolein 107028 0.00263 Ib/MMBtu AP -42, Table 3.2-3 Benzene 71432 0.00158 lb/MM Btu AP -42, Table 3.2-3 Other: 67-56-1 0.00306 lb/MMBtu AP -42, Table 3.2-3 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 'COLORADO 5 I sn_2o,_ Permit Number: AIRS ID Number: 1 23 I / [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 8 - 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 GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. JV afticAo._J Signature of Legally Authorized Person (not a vendor or consultant) Marsha Sonderfan Date EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $1,875, 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 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 k/qR 75 2p19 'Solar; Bey Gas Venting APEN - Form APCD-211. c 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. 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 at: www.colorado.gov/cdphe/apcd. 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: ) ea7,23 AIRS ID Number: 123 /A,03.0 /006 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Fox Creek 33 Compressor Station Site Location: NWNW Section 33, T12N, R63W Mailing Address: (Include Zip Code) Site Location County: Weld NAICS or SIC Code: 131 1 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.com ' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 3547x; cccoenDo 1_(vti F= Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership4 El Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 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: of natural gas. Backup Flare for up to 50 MMscf/year Company equipment Identification No. (optional): For existing sources, operation began on: NA For new, modified, or reconstructed sources, the projected start-up date is: 10/1/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day 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? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week weeks/year Yes Yes Yes 2 N ❑✓ No ❑✓ No COLOR ADO 2 C i �m tiF Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.972465/-104.446879 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (-F) Flow Rate (ACFM) Velocity (ft/sec) FL -1 30 1,831 691 66 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 4 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: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑ Combustion Device: Pollutants Controlled: VOC, HAP Rating: 340 Type: Flare MMBtu/hr Make/Model: Steffes Dual High Pressure High Capacity Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 1,831 Waste Gas Heat Content: 1,362 Btu/scf Constant Pilot Light: ❑ Yes ❑✓ No Pilot burner Rating: NA MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: 0 Form APCD-211 - Gas Venting APEN - Revision 7/2018 (COLORADO 4 Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: Serial #: # of Pistons: Capacity: gal/min Leak Rate: Scf/hr/pist ❑ Blowdown Events # of Events/year: Volume per event: MMscf/event ❑✓ Other Description: Backup Flare for up to 50 MMscf/year of natural gas. If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑✓ No Vent Gas 1 362 BTU/SCF Heating Value: , Requested: 50 MMSCF/year Actual: 50 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 24.10 VOC (Weight %) 33.3105 Benzene (Weight %) 0.0712 Toluene (Weight %) 0.0469 Ethylbenzene (Weight %) 0.0039 Xylene (Weight %) 0.0110 n -Hexane (Weight %) 0.5748 2,2,4-Trimethylpentane (Weight %) 0.0002 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 3 I 4-7,%',:e',.;,-4 :,r Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the erall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM None 0 SOx None 0 NO None 0 CO None 0 VOC Combustion Device 95 HAPs Combustion Device 95 Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions6 ` (tons/year) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions tons/ ear (tons/year) ) PM 40.0 ug/L AP -42 Table13.5 182 0.00 0.00 0.66 SOx 0.02482 lb/MMBtu AP-42Table13.5182 0.00 0.00 0.85 NOx 0.068 Ib/MMBtu AP -42 Table13.5 182 0.00 0.00 2.32 CO 0.310 lb/MMBtu AP -42 Table13.5 1 62 0.00 0.00 10.56 VOC 21,183 Ib/MMscf Eng Est N/A 529.6 26.48 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 45.3 Ib/MMscf Eng Est 2,264 Toluene 108883 29.8 lb/MMscf Eng Est 1,492 Ethylbenzene 100414 2.5 lb/MMscf Eng Est 124 Xylene 1330207 7.0 lb/MMscf Eng Est 350 n -Hexane 110543 365.5 lb/MMscf Eng Est 18,277 2,2,4- Trimethylpentane 540841 0.1Eng lb/MMscf Est 6 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 V,CGLOF.dDO Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorize?ti'erson (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance E✓ 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: 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.pov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 'coLoeaDo 6jA-I�� :y.� Hello