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Home My WebLink About20193762.tiffa COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 August 14, 2019 Dear Sir or Madam: RECEIVED AUG 1 9 2019 WELD COUNTY COMMISSIONERS On August 22, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for HighPoint Operating Corporation - Anschutz Equus Farms 3-62-4 NENE. 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 Po IOU c, vi `el ag49 Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director cc, PL(TP), e_.( -I t Tr), oc, JM3, PWCsrn/CH1LR/CK) '/2-1/19 2019-3762 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Anschutz Equus Farms 3-62-4 NENE - Weld County Notice Period Begins: August 22, 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: Anschutz,Equus Farms 3-62-4 NENE Exploration Et Production Well Pad NENE Quadrant of Section 4, Township 3N, Range 62W Weld County The proposed project or activity is as follows: The Anschutz Equus Farms 3-62-4 NENE facility is a multi -well facility located in the 8 -hour ozone nonattainment area servicing ten new wells. Through this permitting action, the applicant has requested to permit the emissions associated with condensate storage, produced water storage, condensate loadout and an emergency open flare. 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 determined that public comment is warranted because: The applicant has proposed to use an open flare as opposed to an enclosed combustor for the control of gas from separators for well production. The emergency open flare is used to combust produced gas in instances where it cannot be compressed and sent to the sates pipeline 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 19WE0306 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 otPublic Health 6 Environment James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 a till% (COLORADO 2 I Department of Public Health 6 Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: James Ricci 383419 6/5/2018 4/30/2019 Section 01 - Facility Information Company Name: County AIRS ID: HighPoint Operating Corporation 123 Quadrant Section Township Range NENE 4 3N 62 Plant AIRS ID: Facility Name: Location: County: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Section 02 - Emissions Units In Permit Application 9F9E Anschutz Equus Farms 3-62-4 NENE NENE Quadrant of Section 4, Township 3N, Range 62W Weld County Exploration & Production Well Pad Oil & Natural Gas Production & Processing Carbon Monoxide (CO) Yes Particulate Matter (PM) Ozone (110x & VOC) AIRs Point44 Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 002 Condensate Tank Yes 19WE0306.CP1 1 Yes Permit Initial Issuance 003 Produced Water Tank Yes 19WE0307.CP1 1 Yes Permit Initial Issuance 004 Liquid Loading Yes 19WE0308.CP1 1 Yes Permit Initial Issuance 005 Process Flare Steffes Flare Yes 19WE0309.CP1 1 Yes Permit Initial Issuance Emergency Open Flare 007 Natural Gas RICE Yes GP02 1 Permit Initial Issuance Section 03 - Description of Project The Anschutz Equus Farms 3-62-4 NENE facility is a multi -well facility located in the 8 -hour ozone nonattainment area. The first of the ten new wells began producing on March 7, 2018. The Anschutz Equus Farms 3-62-4 NENE serves the commingled liquid stream (contain ng natural gas, crude oil and produced water) from the 10 wells through 3 -phase inlet separators. The inlet separators separate the fluids into individual phases (natural gas, produced water, hydrocarbon liquid). • The hydrocarbon liquid flows first to one of two (2) heated low-pressure separator_ (heater treaters) and then to one of three (3) vapor recovery towers (VRTs) where any entrained gases are allowed to flash from the liquid. The liquid then flows to twelve (10) 400 bbl atmospheric storage tanks. • Any produced water that may be generated is sent to two (2) 400 bbl atmospheric produced water storage tanks directly from the 3 -phase inlet separators. When an adequate volume of water is accumulated, it is sent to a third party commercial disposal facility via trucl• s. • Tank truck loading emissions occur during the loading of the tank trucks for sales from the tank battery. The liquid is subme -ge-filled as it is loaded into the truck. As the liquid is pumped into the truck, the fluid displaces the vapors. The displacement causes the vapors to ve it from inside the truck to the atmosphere. This facility utilizes three (3) 84" Cimarron Big Hurt combustors. The waste gas vapors =rom the crude oil tanks, produced water tanks and truck loading operations are routed to the Cimarron enclosed combustors. This facility also utilizes (1) Steffes emergency gas open flare to combust produced gas in instances where it cannot be compressed and sent to the sales pipeline There is also a 1 ,900 -hp Waukesha L7044GS1 compressor engine at this facility used fcr compression. This engine is covered urde r a GP02. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification is this stationary source a true minor? 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 here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes SO2 NOx CO OC PM2.5 PM10 TSP HAPs No SO2 NOx CO HOC PM2.5 PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 002 Condensate Tank Facility AIRs ID: 123 County 9F9E Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Twelve (12) 400 barrel fixed roof storage vessels used to store condensate Cimarron Big Hurt Enclosed Combustor, 98% Manufacturer Guaranteed control Efficiency 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas/bbl produced = 520,000 624,000 624,000 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year 2186.8273 Btu/scf 7.12 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = PTE heat content of waste gas routed to combustion device = Pilot Gas (50 scf/hr per combustor) Section 04 - Emissions Factors & Methodologies Will this tank emit flash emissions? 11,312 13,232 13,232 1,715 Actual Condensate Throughput While Emissions Controls Operating = 520,000 Barrels (bbl) per year Requested Monthly Throughput = 52997 Barrels (bbl) per month From Flash Liberation From Flash Liberation MMBTU per year MMBTU per year MMBTU per year MMBTU per year Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 7.60E-01 3.80E-02 Site Specific E.F. (includes flash) Benzene 1.81E-03 9.06E-05 Site Specific E.F. (includes flash) Toluene 1.01E-03 5.04E-05 Site Specific E.F. (includes flash) Ethylbenzene 1.25E-04 6.26E-06 Site Specific E.F. (includes flash) Xylene 3.06E-04 1.53E-05 Site Specific E.F. (includes flash) n -Hexane 1.45E-02 7.27E-04 Site Specific E.F. (includes flash) 224 IMP 6.95E-06 3.48E-07 Site Specific E.F. (includes flash) Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/bbl) (waste heat combusted) (Condensate Throughput) PM10 7.45E-03 1.16E-04 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 7.45E-03 1.16E-04 NOx 6.80E-02 1.06E-03 CO 3.10E-01 4.83E-03 Section 05 - Emissions Inventory = VOC Emissions * (1/MW) * 379.41 * (1/VOC%) * Heat Content = VOC Emissions * (1/MW) * 379.41 * (1/VOC%) * Heat Content = VOC Emissions * (1/MW) * 379.41 * (1/VOC%) * Heat Content Flash Liberation TANKS 4.0.9d Flash (lb/bbl) W&B (lb/bbl) Total (lb/bbl) 0.64192 0.118052885 0.7600 0.0015305 0.00028147 0.0018 0.000852048 0.000156698 0.0010 0.000105667 1.9433E-05 0.0001 0.000258298 4.75028E-05 0.0003 0.012275867 0.002257619 0.0145 5.87041E-06 1.07961E-06 0.0000 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) VOC PM10 PM2.5 NOx CO 237.1 197,6 9.9 237.1 11.9 2014 0.0 0.0 0.0 0.0 0.0 8 0.0 0.0 0.0 0.0 0.0 8 0.5 0.4 0.4 0.4 0.4 76 2.3 2.0 2.0 2.1 2.1 348 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 Toluene Ethylbenzene Xylene n -Hexane 224 IMP 1131 942 47 1131 57 629 525 26 629 31 78 65 3 78 4 191 159 8 191 10 9069 7557 378 9069 453 4 4 0 4 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 2 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. N/A Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Yes Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes A pressurized liquid sample was taken on 4/25/2018 at the Anschutz Equus Farms 3-62-4 NENE site. The sample was taken at 8.9 psig / 106 deg F and was labeled, VRT. The pressurized liquid sample was flashed on 5/2/2018 by APT Inc. from 13 psig (separator pressure) / 106 deg F to 12.6 psi / 69 deg F Base conditions were assumed to be 14.65 psi and 60 deg F. The GOR was reported as "SCE" so it was assumed the results had already been converted to standard conditions. An extended gas analysis of the flashed gas was also provided by the applicant which was used to estimate the flash emissions from the condensate tanks. TANKS 4.0.9d was used to estimate Working and Breathing (W&B) losses from the condensate tanks assuming a stored liquid of 7.8 RVP. This was acceptable based on the reported RVP of the stock tank being 7.6. NOx and CO emissions are associated with the enclosed combustor. The equation used (above) to estimate waste case was accepted since it resulted in a conservative (higher) estimation of combustion based compared to using GOR and Heat Content. According to the applicant, "Despite the initial oil samples showing lower API gravity, I reviewed our recent haul tickets and we have pulled loads showing 40 to 41 degrees API. We therefore request to conservatively permit the tanks as condensate instead of crude." Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 002 Process # 01 SCC Code 4-04-003-11 Fixed Roof Tank, Condensate. working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.03 0 lb/1,000 gallons condensate throughput VOC 18.1 95 lb/1,000 gallons condensate throughput CO 0.16 0 lb/1,000 gallons condensate throughput Benzene 0.04 95 Ib/1,000 gallons condensate throughput Toluene 0.02 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.01 95 lb/1,000 gallons condensate throughput n -Hexane 0.35 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 3 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex= Q* MW *Xx/C Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm MW 44.66 Ib/Ib-mol Throughput 1 bbl/year Gas -to -Oil Ratio (GOR) 7.1246 scf/bbl mass fraction (%) Emission Factor (lb/bbl) Emissions (lbs/year) Oxygen/Argon 2.86 2.399E-02 0.02 CO2 0.74 6.208E-03 0.01 N2 11.12 9.328E-02 0.09 H2S 0.00 0.000E+00 0.00 methane 1.77 1.481E-02 0.01 ethane 6.97 5.843E-02 0.06 propane 29.24 2.452E-01 0.25 isobutane 6.24 5.230E-02 0.05 n -butane 21.98 1.843E-01 0.18 isopentane 5.52 4.630E-02 0.05 n -pentane 6.36 5.334E-02 0.05 cyclopentane 0.54 4.500E-03 0.00 n -Hexane 1.46 1.228E-02 0.01 cyciohexane 0.31 2.565E-03 0.00 Other hexanes 2.72 2.285E-02 0.02 heptanes 0.89 7.446E-03 0.01 methylcyclohexane 0.27 2.286E-03 0.00 224-TMP 0.00 5.870E-06 0.00 Benzene 0.18 1.530E-03 0.00 Toluene 0.10 8.520E-34 0.00 Ethylbenzene 0.01 1.057E-34 0.00 Xylenes 0.03 2.583E-34 0.00 C8 0.35 2.958E-33 0.00 C9 0.05 4.537E-34 0.00 C10 0.28 2.374E-33 0.00 C11+ 0.00 0.000E-30 0.00 Total 100.00 /ter,,,: <. VOC Wt % 76.54_ 0.6419 0.00032 n -Hexane 224 -TM P Benzene Toluene Ethylbenzene Xylenes otal GOR Conversion Check Actual Pressure (P1) 1 psia Actual Temperature (T1) 1 Rankine Actual GOR (V1) 1 cf/bbl Standard Pressure (P2) 1 psia Standard Temperature (T2) 1 Rankine Standard GOR (V2) 1 scf/bbl 87.52 8.816E+01 Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B • APEN and Permit Re uirements S'urce is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY iRegulation 3, Part A, Section II.D.1-a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memc 05-01 Definitions 1.12 and1.14 and Section 2 for additional gt 'dance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions gwater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional gt.idance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source n•auires a permit Yes No Colorado Regulation 7, Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor ration or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? :orage tank is subject to Regulation 7, Section xIi C F Yes Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C2 - Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII.G Section XII.G2 - Emissions Control Requirements Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C2 - Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well product on facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC? -rase tank R subject to Regulation 7, Section XVII, B. C.1 & C.3 Yes Yes NO Yes 'F Yes Yes Section XVII.B -General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Storage tank is subject to Regulation 7, Section XVII.C.2 Yes Section XVII.C2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m') ["472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m' [`10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to :ustody transfer= as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.1 llb? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.11lb? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' ('950 BBL] and stores a liquid with a maximum true vapor pressures less than 35 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' [`472 BBL) but less than 151 m1 ("-950 BBL] and stores a liquid with a maximum true vapor pressure' less tnan 15.0 kPa(60.110b(b))? No No NA NA NA NA NA Source Req Go to next Source Req Continue -' Continue -' Source is st Continue -' Storage Tar Source is st Continue-' Go to the n Go to the n Source is st Source is st Storage Tar Storage Tank is not subject to NSPS hm Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) bet peen August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Fart 60 Subpart Kb or 40 CFR Part 63 Subpart RH? Storage Tank is not subject to NSPS 0000 NA NA NA No No NA Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 ons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year) 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MACT HH Subpart A, General provisions per §63.764 (a) Table §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting NA No NA NA RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act. its implementing regulations, and Air Quality Control Commission regulations- This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation eased 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 descnbe APCD interpretations and recommendations Mandatory terminology _uch as "must" and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legac=y binding requirements in and of itself NA Continue-' Storage Tar Storage Tar Continue-' Storage Tar Produced Water Storage Tank(s) Emissions Inventory 003 Produced Water Tank Facility AIRs ID: 123 • 9F9E County Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Contrc I Efficiency %: Two (2) 400 barrel fixed roof storage vessels used to store producec water Cimarron Big Hurt Enclosed Combustor, 98% Manufacturer Guaranteed Control Efficiency 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas/bbl produced = 760,000 912,500 912,500 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year 977.9691 Btu/scf 1.39 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = PTE heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this tank emit flash emissions? Yes 1,033 1,240 1,240 Actual Produced Water Throughput While Emissions Controls Operating = Requested Monthly Throughput = 77500 Barrels (bbl) per month From Flash Liberation From Flash Liberation MMBTU per year MMBTU per year MMBTU per year Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled Emission Factor Source (Ib/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 1.42E-02 7.09E-04 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific ES. (includes flash) Site Specific E.F. (includes flash) Benzene 2.63E-04 1.32E-05 Toluene 1.58E-04 7.88E-06 Ethylbenzene 1.66E-05 8.31E-07 Xylene 3.71E-05 1.85E-06 n -Hexane 1.59E-04 7.94E-06 224 TMP 8.80E-06 4:40E-07 Pollutant Control Device Emission Factor 5 urce Uncontrolled Uncontrolled (Ib/M V16tu) (lb/bbl) (waste heat combusted) (Produced Water Throughput) PM10 7.45E-03 1.01E-05 AP -42 Table 1.4-2 (PM10/PM 2.5) AP 42 Table 1.4-2 (PM1O/PM.2 5) AP -42 Chapter 13.5 Industrial ftares (NOx) AP -42 Chapter 13.5 industrial Flares (CO) PM2.5 7.45E-03 1.01E-05 NOx 6.80E-02 9.24E-05 CO 3.10E-01 4.21E-04 Section 05 - Emissions Inventory Flash Liberation TANKS 4.0.9d Flash (lb/bbl) W&B (lb/bbl) Total (lb/bbl) 0.01418 0 0.0142 0.000263043 0 0.0003 0.000157687 0 0.0002 1.66195E-05 0 0.0000 3.70971E-05 0 0.0000 0.000158874 0 0.0002 8.80437E-06 0 0.0000 Criteria Pollutants Potential to Emit Uncontrolled (tons/ year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrol ed Controlled (tons/veer) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 6.5 5.4 0.3 6.5 0.3 55 0.0 0.0 0.0 0.0 0.0 1 0.0 0.0 0.0 0.0 0.0 1 0.0 0.0 0.0 0.0 0.0 7 0 2 0.2 0.2 0.2 0.2 33 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/near) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrol'ed Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 240 200 10 240 12 1414 120 6 144 7 1.5 13 1 15 1 34 28 1 34 2 145 121 6 145 7 E 7 0 8 0 Section 06 - Regulatory Summary Analysis 760,000 Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart OC 00 _Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 6 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally mean; site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specif c emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and init al compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes A pressurized liquid sample was taken on 4/25/2018 at the Anschutz Equus Farms 3-62-4 NENE site. The sample was taken at 193 psig / 107 deg F and was labeled, 2417C. The pressurized liquid sample was flashed on 5/2/2018 by APT Inc from 193 psig (separator pressure) / 107 deg F to 12.6 psi ,' 60 deg F. Base conditions were assumed to be 14.65 psi and 60 deg F. The GWR was reported as "SCF" so it was assumed the results had already been converted to standard conditions. An extended gas analysis of the flashed gas was also provided by the applicant which was used to estimate the flash emissions from the condensate tanks. Based on PS Memo 14-03, only the flash liberation analysis is required when developing site specific emission factorsfor produced water tanks. W&B Losses are assumed to be negligible NOx and CO emissions are associated with the enclosed combustor. Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code Cl 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Pollutant PM10 PM2.5 NOx VOC CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.00 0.3 0.01 0.01 0.00 0.00 0.00 0.00 0.00 Control % 0 0 0 95 0 95 95 95 95 95 95 Units lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput liquid throughput 7 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 EPA Emission InventDry Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW*Xx/C Ex = emissions of polutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas = SG of gas * MW of air Xx = mass fraction of x in gas C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm MW 26.9056 Ib/Ib-mol bbl/year scf/bbl Throughput 1 Gas -to -Oil Ratio (GO3) 1.395 mass fraction (%) Emission Factor (lb/bbl) Emissions (lbs/year) Oxygen/Argon 0.00 0.000E-00 0.00 CO2 38.09 3.768E-02 0.04 N2 2.13 2.104E-03 0.00 H2S 0.00 0.000E-00 0.00 methane 33.71 3.335E-02 0.03 ethane 11.73 1.160E-02 0.01 propane 8.85 8.753E-03 0.01 isobutane 0.76 7.472E-04 0.00 n -butane 2.46 2.432E-03 0.00 isopentane 0.38 3.771E-04 0.00 n -pentane 0.44 4.355E-04 0.00 cyclopentane 0.13 1.248E-04 0.00 n -Hexane 0.16 1.589E-04 0.00 cyclohexane 0.07 7.093E-05 0.00 Other hexanes 0.28 2.813E-04 0.00 heptanes 0.08 7.845E-05 0.00 methylcyclohexane 0.05 4.818E-05 0.00 224-TMP 0.01 8.804E-36 0.00 Benzene 0.27 2.630E-34 0.00 Toluene 0.16 1.577E-34 0.00 Ethylbenzene 0.02 1.662E-05 0.00 Xylenes 0.04 3.710E-05 0.00 C8 0.06 6.163E-05 0.00 C9 0.02 2.216E-05 0.00 C10 0.11 1.088E-04 0.00 C11+ 0.00 0.000E+00 0.00 Total V0C Wt % 100.00 14.34 0.0142 0.00001 n -Hexane 224 -TM P Benzene Toluene Ethylbenzene Xylenes Total GOR Conversion Check Actual Pressure (P1) 1 psia Actual Temperature (T1) 1 Rankine Actual G0R (V1) 1 cf/bbl Standard Pressure (P2) 1 psia Standard Temperature (T2) 1 Rankine Standard G0R (V2) 1 scf/bbl 87.52 8.753E+01 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the :anks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Part≤ A and B - APEN and Perrnit Reouirernents Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section 11.0.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? w,ca was Yes You have incicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II D.1.a)? 2. Is the operator claiming ess than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? No Yes Source requires a permit Colorado Regulation 7, Sect on XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station3 or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Yes Yes Yes Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVI1.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart OO3O, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced wate- storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissons2 from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Yes No No NA Storage Tani+ is not subject to NSPS OOOO Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and :losed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] RACT Review RAG review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criterk, then review RAG requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, cr any other legally binding requirement and is not legally enforceaale. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," "should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Go to next Source Req Continue -' Continue -' Go to the n Source is st Source is st Continue -' Storage Tar Storage Tar Hyd-ocarbon Loadout Emissions Inventory 004 liquid Loading Facility AIRs ID: 123 County 9F9E Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Truck loadout of condensate by submerged fill, into tank Trucks Emission Control Device Cimarron Big Hurt Enclosed Combustor, 98% Manufacturer Guaranteed Control Efficiency Description: Is this loadout controlled? Yes Collection Efficiency: 100.0 Control Efficiency: 95 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded = 520,000 624,000 624,000 Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2187 Btu/scf Volume of waste gas emitted per year = 1085484 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility oeing permitted? Loading Loss Equation L = 12.46*S*P*M/T 1,978 2,374 2,374 Actual Volume Loaded While Emissions Controls Operating = 520,000 Requested Monthly Throughput = 5299/ Barrels (bbl) per month MMBTU per year MMBTU per year MMBTU per year Barrels (bbl) per year = VOC Emissions * (1/MW) * 379.41 * (1/VOC%) * Heat Content = VOC Emissions * (1/MW) * 379.41 * (1/VOC%) * Heat Content = VOC Emissions * (1/MW) * 379.41 * (1/VOC%) * Heat Content The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor ,) :,lf f ? P True Vapor Pressure 3.7882 psia Average TVP from TANKS 4.0.9d based on RVP = 7.8 M Molecular Weight of Vapors 68 lb/lb-mol AP -42 Chapter 7 Table 7.1-2 based on RVP = 7.8 T Liquid Temperature 512.45 Rankine Liquid Bulk Temp from TANKS 4.0.9d based on RVP = 7.8 L Loading Losses 3.758024505 lb/1000 gallons 0.157837029 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.00238 0.000316326 lb/bbl VRT Gas Flash Liberation HAP/VOC Ratio Toluene 0.00133 0.000209505 lb/bbl VRT Gas Flash Liberation HAP/VOC Ratio Ethylbenzene 0.00016 2.59819E-05 lb/bbl VRT Gas Flash Liberation HAP/VOC Ratio Xylene 0.00040 6.35114E-05 lb/bbl VRT Gas Flash Liberation HAP/VOC Ratio n -Hexane 0.01912 0.003018442 lb/bbl VRT Gas Flash Liberation HAP/VOC Ratio 224 TMP 0.00001 1.44344E -0F lb/bbl VRT Gas Flash Liberation HAP/VOC Ratio Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (Ib/bbl) (lb/bbl) Emissior Factor Source (Volume Loaded) (Volume Loaded) VOC 1.58E-01 7,89E-03 Site Specific - AP -42: C-apter 5.2, Equation 1 Benzene 3.76E-04 1.83E-05 Site Specific - AP -42: C-apter 5.2, Equation 1 Toluene 2.10E-04 1.05E-05 Site Specific - AP -42: C-apter 5.2, Equation 1 Ethylbenzene 2.60E -OS 1.30E-06 Site Specific - AP -42: Chapter 5.2, Equation 1 Xylene 6.35E-05 3.18E-06 Site Specific - AP -42: C-apter 5.2, Equation 1 n -Hexane 3.02E-03 1.51E-04 Site Specific - AP -42: C-apter 5.2, Equation 1 Site Specific - AP -42: C -apter 5.2, Equation 1 224 TMP 1.44E-06 7.22E-08 Control Device Emission =actor Source Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 7.45E-03 2.83E-05 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (5O,) AP -42 Chapter 133 Ind _Istria! Flares (NOx) AP -42 Chapter 13.5 Ind _Istria! Flares (CO) PM2.5 7.45E-03 2.83E-05 SOx 5.88E-04 2.24E-06 NOx 6.80E-02 2.59E-04 CO 3.10E-01 1.18E-03 10 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 Hydrocarbon Loadout 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 (Ibs/mcnth) PM10 PM2.5 SOx NOx VOC CO 0.0 0.0 0.0 0.0 0.0 2 0.0 0.0 0.0 0.0 0.0 2 0.0 0.0 0.0 0.0 0.0 0 0.1 0.1 0.1 0.1 0.1 14 49.2 41.0 2.1 49.2 2.5 41E 0.4 0.3 0.3 0.4 0.4 52 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 235 196 10 235 12 Toluene 131 109 5 131 7 Ethylbenzene 16 14 1 16 1 Xylene 40 33 2 40 2 n -Hexane 1884 1570 78 1884 94 224 TMP 1 1 0 1 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section III.D.2.a The loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes A sales oil sample was taken on 4/25/2018 at the Anschutz Equus Farms 3-62-4 NENE site. The sample was taken at 69 deg F and was labeled, Storage Tank. The sales oil sample was analyzed on 4/27/2018 by APT Inc. Based on ASTM D6377, the sales oil has a RVP of 7.6. Values used in the AP -42 liquid loading equation were based on a RVP of 7.8, this was accepted as a conservative estimate. The control system during loadout is a bit of a hybrid between direct to combustors and vapor balance. The vapors are routed back to a knockout between the tanks and the combustors. The applicant did not agree with checking vapor balance on the APEN but it's the closest description on the O&M to what's happening. NOx and CO emissions are associated with the enclosed combustor. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # 01 -xxe3ei kx% xnxxxxa"xxxR. Ri.'SSRK xt%RxxxJ:xessncxjYeR9.e +%xx%c �%t`KXX, (�a .�.=- %%x�txt�, •` t r %tx, y, A' %. dx15tYRA zx T YE%s>S L 'RAx'3y¢I,X;x, %Agrq't XJw'siX xxXxxna9tx%- x xx 1 uY..'g �e. x Jrr %s 3s xZx , 2z c A.ix��tiX SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 Ib/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0.00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 3.8 95 lb/1,000 gallons transferred CO 0.03 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 Ib/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.07 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 11 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements Source is in the Nan•Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per cay on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via su mmerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? ?c,u have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater thar 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per cay on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via suomerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TDY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Yes No No No Yes Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulat on 3, Part B, Section III.D.2.a)? Yes The loadout must operate with submerged fill and loadout emissions must be roused to flare to satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requ.rements 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 partict.lar 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 enforceaole 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 '.ie 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 inte"ided to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does n pt establish legally binding requirements in and of itself Go to next Go to the n Go to next Go to next Go to next The loadou The loadou Separator Venting Emissions Inventory 005 Separator Venting Facility AIRs ID: 123 County 9F9E Plant 005 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: (1) Steffes emergency gas flare to combust produced gas during compressor downtime or pipeline unavailability Emission Control Device Description: Steffes Open Flare, 98% Manufacturer Guaranteed Control Efficiency Requested Overall VOC & HAP Control Efficiency %: 95 Limited Process Parameter Natural Gas Vented Gas meter Yes, meter is currently installed and operational Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: MMscf per year 50.0 MMscf per year 0 MMscf per year Requested Monthly Throughput = MMscf per month Uncontrolled and controlled emiss ons used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) 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 1188 Btu/scf scf/bbl Net Dry Real BTU, from Gas Analysis A sample of Sales Gas was take from the Anschutz Equus Farms 3-62-4 NENE facility on 4/25/18 and analyzed by ATP on 5/1/18. The sample was take at 189 psig and 89 deg F. An extended gas analysis was provided by the applicant, the Weight %'s from this analysis can be seen below. MW 22.94 lb/lb-mol Displacement Equation Ex = Q * MW * Xx / C Weight % Helium 0.02 CO2 4.79 N2 0.85 methane 50.64 ethane 15.59 propane 15.59 isobutane 1.87 n -butane 5.52 isopentane 1.18 n -pentane 1.40 cyclopentane 0.13 n -Hexane 0.41 cyclohexane 0.11 Other hexanes 0.73 heptanes 0.39 methylcyclohexane 0.14 224 -IMP 0.00 Benzene 0.06 Toluene 0.06 Ethylbenzene 0.01 Xylenes 0.03 C8+ Heavies 0.48 Total 100.UL VOCWt% 28.11 Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 15994.3 849.7 Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Extended gas analysis Benzene 3.70E+01 1.85E+00 Toluene 3.66E+01 1.83E+00 Ethylbenzene 6.05E+00 3.02E-01 Xylene 1.58E+01 7.89E-01 n -Hexane 2.45E+02 1.22E+01 224 TMP 1.21E-01 6.05E-03 Primary Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) Ib/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 7.45E-03 8.85E+00 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 7.45E-03 8.85E+00 SOx 5.88E-04 6.99E-01 NOx 6.80E-02 8.08E+01 CO 3.10E-01 3.68E+02 13 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 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 PM2.5 SOx NOx VOC 0.2 0.0 0.0 0.2 0.2 38 0.2 0.0 0.0 0.2 0.2 38 0.0 0.0 0.0 0.0 0.0 3 2.0 0.0 0.0 2.0 2.0 343 424.9 0.0 0.0 424.9 21.2 3608 CO 9.2 0.0 0.0 9.2 9.2 1563 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 1850 0 0 1850 93 Toluene 1832 0 0 1832 92 Ethylbenzene 302 0 0 302 15 Xylene 789 0 0 789 39 n -Hexane 12247 0 0 12247 612 224 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 gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it 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? Yet. 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. r �S ✓ /.' ./, �C•-•-r. /'vr, r., 5/•'.-. .'y r�r> ii/ii,�r%/ ii // /!'/ter',�i. �!r�.�` `;%✓� ;,,: �r ! '. ' r//r:� `. �i %/r ice , :Q t♦ -,S . o L r`� --♦ f -P Yil f'•. { ♦ e f! A b s .. f�.�♦ 6)" i G7 'r♦ ./'• . •/ r /1'%/i'i•xr'�!/,.• '59t�iJ' ? �5 4' .riy. ,q / .j.. L ;g J a 7L r a%i1 a' o N♦ r ^/: quo .•,,.„.. a Lr ../. e J s >A Sd • C/ V /,..Y ♦ tt 7 -� ! S l of 4 f t,v ♦ i .v l ( / l %,✓/// //i ,! / /I /, /,'/%�,/ //�/s� /.v'�% s,(ii -*iv: ,!4%7A . l.{�, ../,(P/4.1174>i/0/e//t,/ .f / ci /if„ r / , /c/r 1. af7ni t'f.C• iii 74, i/ /i✓// % i,, /.i• C i/.:: 1.. ' •71.47f>�'j6t!///$ r >^ 9 /'t• s ' S /� ,/ /{Jg-// / r, ,, :C• 5$ s q �/{%%/J(J/JJ/ / h%//�%/ !/ {/,"//.%;r%////%..%./"/' / ...>/�%..i""/•/773; ".,'. iso 14 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes �...i .. .... .. ... M ±v.. .. Y•WAC, HW3X.v.W.✓ n)YHWYN+! `w .—mri si.w •rl r.i.rYN✓F/ WM/3".*WWYCH •• M .. Y The applicant submitted an Alternative Emissions Control Equipment Request Form for permission to control the combustion of this produced gas with an open flare. This open flare will only be used as back-up control during non -routine operating conditions. The emergency gas flare has a flow meter to measure the volume of gas sent to the flare, this volume is measure hourly by SCADA. Operation of this flare will be limited to 744 hours per year. The applicant has confirmed the gas meter is already installed and operational. Since it was not clear where the gas sample provided with the application was taken and if it represented all the streams ofgas that could be combusted, I requested another sample from the applicant to verify. HighPoint provided the gas analysis from the most recent flare meter calibration (Report Date 6/06/2019). This sample contained less VOC than the original gas analysis supplied with the application. Since it was still not clear if this 2nd sample was a comingled stream and representative of all the gas streams that could be combusted during emergency flaring, initial compliance testing will be required in the permit. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 8.85 0 lb/MMSCF PM2.5 8.85 0 Ib/MMSCF SOx 0.70 0 Ib/MMSCF NOx 80.75 0 lb/MMSCF VOC 16994.28 95 lb/MMSCF CO 368.14 0 Ib/MMSCF Benzene 37.00 95 lb/MMSCF Toluene 36.64 95 lb/MMSCF Ethylbenzene 6.05 95 Ib/MMSCF Xylene 15.78 95 Ib/MMSCF n -Hexane 244.94 95 Ib/MMSCF 224 TMP 0.12 95 Ib/MMSCF 15 of 16 H:\World\Working\Package 383419 - Highpoint Equus\19WE0306.CP1\19WE0306.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or C: emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater thar 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 T::'Y or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Yes Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, ;014? 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 En tssions 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? Yes 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 particLiar 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 'erminology such as "must" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does ,iot establish legally binding requirements in and of itself. Source Req Source Req Source is st The contro COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: CONSTRUCTION PERMIT 19WE0306 Issuance: 1 XX Issued to: High Point Operating Corporation Facility Name: Anschutz Equus Farms 3-62-4 NENE Plant AIRS ID: 123-9F9E Physical Location: NENE Quadrant of Section 4, Township 3N, Range 62W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Emissions Control Description AIRS Point Equipment Description 002 Twelve (12) 400 barrel fixed roof storage vessels used to store condensate Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 for the equipment covered by this permit. 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 Number 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. A self certification form and guidance on how to self -certify Page 1 of 10 COLORADO Air Pollution Control Division Department of Pubiic Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Qov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section 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. (Regulation Number 3, Part B, Section III.F.4.) 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. (Regulation Number 3, Part B, Section III.E.) 5. 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 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A 4 ) Annual Limits: AIRS Point Tons per Year Emission Type VOC CO 002 11.9 2.1 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 002 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits AIRS Point Process Parameter Annual Limit 002 Condensate Throughput 624,000 barrels The owner or operator shall monitor monthly process rates based on the calendar month. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING a MAINTENANCE REQUIREMENTS 16. 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 the oak plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (N0,0 in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation No. 3, Part D shall apply, at such time that any stationary source or modification becomes a major stationary source or major modification Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Permit Number AIRS Point Equipment Description Pollutant Emissions (tpy) Threshold Current Permit Limit 19WE0306.CP1 002 Condensate Storage VOC 11.9 19WE0307.CP1 003 Produced Water Storage VOC 0.3 19WE0308.CP1 004 Condensate Loadout VOC 100 tpy (NANSR) 2.5 19WE0309.CP1 005 Emergency Flare VOC 21.2 GP02 007 RICE VOC 12.8 19WE0306.CP1 002 Condensate Storage NOx 0.5 19WE0307.CP1 003 Produced Water Storage NOx 0.0 19WE0308.CP1 004 Condensate Loadout NOx 100 tpy (NANSR) 0.1 19WE0309.CP1 005 Emergency Flare NOx 2.0 GP02 007 RICE NOx 12.8 GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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 Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the. Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for condensate storage at a synthetic minor facility in the non -attainment area. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator 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. AIRS Point Pollutant CAS # Uncontrolled Emissions ' (lb/yr) ' Controlled Emissions (lb/yr) 002 Benzene 71432 1131 57 Toluene 108883 629 31 Ethylbenzene . 100414 78 4 Xylenes 1330207 191 10 n -Hexane 110543 9069 453 2,2,4-Trimethylpentane 540841 4 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.06 x 10-3 AP -42 Chapter 13.5 CO 4.83 x 10-3 VOC 7.60 x 10"1 3.80 x 10-2 Flash Liberation of a Site Specific Liquid Sample + 4.0.94 71432 Benzene 1.81 x 10-3 9.06 x 10-5 108883 Toluene 1.01 x 10-3 5.04 x 10-5 100414 Ethyibenzene 1.25 x 10"4 6.26 x 10"6 1330207 Xylene 3.06 x 1 ?" 1.53 x 10-5 110543 n -Hexane 1.45 x 10-2 7.27 x 10-4TANKS 540841 2,2,4-Trimethylpentane 6.95 x 10 _ 3.48 x 10' Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, n -Hexane NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source MACT HH Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Page 9 of 10 CDPHE COLORADO Air Pollution Control Division epartmert of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0307 Date issued: Issued to: Issuance: 1 is HighPoint Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: Description: Anschutz Equus Farms 3-62-4 NENE 123-9F9E NENE Quadrant of Section 4, Township 3N, Range 62W Weld County Well Production Facility Equipment or activity subject to this permit: Emissions Control Description AIRS Point Equipment Description 003 Two (2) 400 barrel fixed roof storage vessels used to store produced water Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 for the equipment covered by this permit. 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 Number 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. A self certification form and guidance on how to self -certify Page 1 of 10 COLORADO Air Pollution Control Division Department of Pubic Heaithb Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit 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. (Regulation Number 3, Part B, Section III.F.4.) I. F.4. ) 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. (Regulation Number 3, Part B, Section III.E.) 5. 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 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Point VOC (tons per year) Emission Type 003 0.3 Point Note: See "Notes to Permit Hodder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health t Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 003 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This sourceshall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits AIRS Point Process Parameter Annual Limit 003 Produced Water Throughput 912 500 barrels The owner or operator shall monitor monthly process rates based on the calendar month. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (08M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health b Frnironment Dedicated to protecting and improving the health and environment of the people of Colorado With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Permit Number AIRS Point Equipment Description Pollutant Emissions (tpy) Threshold Current Permit Limit 19WE0306.CP1 002 Condensate Storage VOC 100 tpy (NANSR) 11.9 19WE0307.CP1 003 Produced Water Storage VOC 0.3 19WE0308.CP1 004 Condensate Loadout VOC 2.5 19WE0309.CP1 005 Emergency Flare VOC 21.2 GP02 007 RICE VOC 12.8 19WE0306.CP1 002 Condensate Storage NOx 0.5 19WE0307.CP1 003 Produced Water Storage NOx 0.0 19WE0308.CP1 004 Condensate Loadout NOx 100 tpy (NANSR) 0.1 19WE0309.CP1 005 Emergency Flare NOx 2.0 GP02 007 RICE NOx 12.8 GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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 Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. , requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for produced water storage at a synthetic minor facility in the non -attainment area. Page 7 of 10 COLORADO Air Pollution Control Division Department of Pubhic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator 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 11.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 240 12 Toluene 108883 144 7 Ethylbenzene 100414 15 1 Xylenes 1330207 34 2 n -Hexane 110543 145 7 2,2,4-Trimethylpentane 540841 8 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Heath 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 9.24 x 10-5 AP -42 Chapter 13.5 CO 4.21 x 10-4 VOC 1.42 x 10-2 7.09 x 10-4 Flash Liberation of a Site Specific Sample 71432 Benzene 2.63 x 10-4 1.32 x 10"5 108883 Toluene 1.58 x 10-4 7.88 x 10-6 100414 Ethylbenzene 1.66 x 10"5 8.31 x 10-' 1330207 Xylene 3.71 x 10"5 1.85 x 10-6 110543 n -Hexane 1.59 x 10-4 7.94 x 10-6 540841 2,2,4-Trimethylpentane 8.80 x 10-6 4.40 x,10"' Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shalt be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, n -Hexane NANSR Synthetic Minor Source of: VOC, NOx PSD True Minor Source MACT HH Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health &Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0308 Issuance: 1 HighPoint Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: Description: Anschutz Equus Farms 3-62-4 NENE 123-9F9E NENE Quadrant of Section 4, Township 3N, Range 62W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 004 Truck loadout of condensate by submerged fill Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 for the equipment covered by this permit. 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 Number 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. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. 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 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: AIRS Point VOC (tons per year) Emission Type 004 2.5 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 004 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. 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 Number 3, Part B, II.A.4) Process/Consumption AIRS Point Process Parameter Annual Limit 004 Condensate Loaded 624,000 barrels The owner or operator shall calculate monthly process rates based on the calendar month. 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. 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.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Inspect thief hatch seats annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 14. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) Page 4 of 10 COLORADO Air Pollution Control Division Department of Pubiic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B) With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Permit Number AIRS Point Equipment Description Pollutant Emissions (tpy) Threshold Current Permit Limit 19WE0306.CP1 002 Condensate Storage VOC 100 tpy (NANSR) 11.9 19WE0307.CP1 003 Produced Water Storage VOC 0.3 19WE0308.CP1 004 Condensate Loadout VOC 2.5 19WE0309.CP1 005 Emergency Flare VOC 21.2 GP02 007 RICE VOC 12.8 19WE0306.CP1 002 Condensate Storage NOx 0.5 19WE0307.CP1 003 Produced Water Storage NOx 0.0 19WE0308.CP1 004 Condensate Loadout NOx 100 tpy (NANSR) 0.1 19WE0309.CP1 005 Emergency Flare NOx 2.0 GP02 007 RICE NOx 12.8 GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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 Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for condensate loadout at a synthetic minor facility in the non -attainment area. Page 7 of 10 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator 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 E.1 of the Common Provisions Regulation. See::https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Benzene 71432 235 12 Toluene 108883 131 7 004 Ethylbenzene 100414 16 1 Xylenes 1330207 40 2 n -Hexane 110543 1884 94 2,2,4-Trimethylpentane 540841 1 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of P-ubhc Heath Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 2.59 x 10'3 AP -42, Chapter 13.5 CO 1.18 x 10 VOC 1.58 x 10-1 7.89 x 10-3 AP -42, Chapter 5.2 Benzene 71432 3.76 x 10"4 1.88 x 10-5 VRT flash liberation vapors HAP/VOC Ratio * AP 42, Chapter 5.2 VOC Emissions Toluene 108883 2.10 x 10"4 1.05 x 10"5 Ethylbenzene 100414 2.60 x 10-5 1.30 x 10-6 Xylene 1330207 6.35 x 10-5 3.18 x 10' n -Hexane 110543 3.02 x 10-3 1.51 x 10-4 2,2,4-Trimethylpentane 540841 1.44 x 10-6 7.22 x 10-8 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 3.7882 psia M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 512.45 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the VRT flash liberation vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 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) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, n -Hexane NANSR Synthetic Minor Source of: VOC, NOx Page 9 of 10 PSD COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.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 61600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ -' Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0309 Issuance: 1 Date issued: )Q( Issued to: HighPoint Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: Description: Anschutz Equus Farms 3-62-4 NENE 123-9F9E NENE Quadrant of Section 4, Township 3N, Range 62W Weld County Well Production Facility Equipment or activity subject', to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Steffes Flare 005 One (1) Steffes emergency gas flare to combust produced gas during compressor downtime or pipeline unavailability Open Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 for the equipment covered by this permit. 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 Number 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 Page 1 of 11 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 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. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 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. (Regulation Number 3, Part B, Section III.E.) 5. 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 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type NOX VOC CO Steffes Flare 005 2.0 ` 21.3 9.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 11 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled Steffes Flare 005 Produced gas is routed to an Open Flare during compressor downtime or pipeline unavailability VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Equipment ID AIRS Point Process Parameter Annual Limit Steffes Flare 005 Natural Gas Venting 50 MMSCF 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. 10. 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 11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 12. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 3 of 11 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 13. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16, and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The owner or operator will monitor and record the usage of the open flare. The usage of the open flare must be limited to 744 hours (1 month) in a calendar year. The permit holder will calculate the total hours of usage per calendar year and keep a compliance record on site or at a local field office with site responsibility, for Division review. (Regulation Number 7, Section XVII.B.2.e.) 15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (0&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0ftM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner/operator shall complete a 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. If an analysis during emergency flaring cannot be performed within one hundred and eighty days (180) after issuance of this permit, a representative analysis may be performed In order to verify the VOC content (weight fraction) of this emission stream, the analysis shall be representative of all the natural gas stream(s) routed to the open flare during both Page 4 of 11 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado compression downtime and during instances of pipeline unavailability. 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). 18. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 19. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 20. A revised Air Pollutant Emission Notice (APEN) shalt be filed: II.C.) (Regulation Number 3, Part A, Annually by April 30th whenever a significant increase in emissions occurs as For any criteria pollutant: follows: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Page 5 of 11 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Permit Number AIRS Point Equipment Description Pollutant Emissions (tpy) Threshold Current Permit Limit 19WE0306.CP1 002 Condensate Storage ' VOC 100 tpy (NANSR) 11.9 19WE0307.CP1 003 Produced Water Storage VOC 0.3 19WE0308.CP1 004 Condensate Loadout VOC 2.5 19WE0309.CP1 005 Emergency Flare VOC 21.2 GP02 007 RICE VOC 12.8 19WE0306.CP1 002 Condensate Storage NOx 100 tpy (NANSR) 0.5 19WE0307.CP1 003 Produced Water Storage NOx 0.0 19WE0308.CP1 004 Condensate Loadout NOx 0.1 19WE0309.CP1 005 Emergency Flare NOx 2.0 GP02 007 RICE NOx 12.8 GENERAL TERMS AND CONDITIONS 22. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 23. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not Page 6 of 11 COLORADO Air Pollution Control Division Department of Public Health t Environment Dedicated to protecting and improving the health and environment of the people of Colorado provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 24. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 25. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 26. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shalt 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 Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution. Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Page 7 of 11 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for the emergency flare located at a synthetic minor facility in the non -attainment area. Page 8 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator 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 Emissions (lb/yr) Controlled Emissions (lb/yr) Steffes Flare 005 Benzene 71432 1850 93 Toluene 108883 1832 92 Ethylbenzene 100414 302 15 Xylenes 1330207 789 39 n -Hexane 110543 12247 612 2,2,4-Trimethylpentane 540841 6 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 9 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 8.08 x 10' AP 42 CO 3.68 x 102 VOC 16, 994.3 849.7 Extended sales gas analysis 71432 Benzene 3.70 x 101 1.85 x 10° 108883 Toluene 3.66 x 10' 1.83 x 10° 100414 Ethylbenzene 6.05 x 10° 3.02 x 10-1 1330207 Xylene 1.58 x 101 7.89 x 10-1 110543 n -Hexane 2.45 x 102 1.22 x 10' 540841 2,2,4-Trimethylpentane 1.21 x 10-' 6.05 x 10"3 Note: The controlled emissions factors for this point are based on open flare control efficiency of 95%. The emission factors listed above are based on a sales gas temperature of 89°F and a sales gas pressure of 189 psig. 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)-692-315O. 7) This facility is classified as follows: the Applicable Requirement Status Operating Permit Synthetic Minor Source of: NOx, VOC, CO, n -Hexane NANSR Synthetic Minor Source of: NOx and VOC PSD True Minor Source 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr.gpoaccess.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 Page 10 of 11 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 11 of 11 cup( Scapa ' SQ -kk,,03. kPEI\1 Crude Oil Storage Tank(s) APEN - Form APCD-210 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 tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. 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. eces,J QJ- Permit Number: I `' l'VEl j3(116 AIRS ID Number: t3 /1F -9E/ ©b2. [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz Equus Farms 3-62-4 NENE Site Location: NENE Section 4 T3N R62W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Marsha Sonderfan Phone Number: 303-312-8524 E Mail Address2: CDPHE_Corr@hpres.com I 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 APCD via e-mail to the address provided. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 383413 COLORADO 1 i awz�� / Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source • Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership' LI Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 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: For existing sources, operation began on: Crude Oil Tank Battery For new or reconstructed sources, the projected start-up date is: 3/7/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ✓❑ Exploration Et Production (EEtP) site ❑ Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Are Flash Emissions anticipated from these storage tanks? El Yes ■ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No III Fl Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 COLORADO /'J� o�vuwc 2 4Y !aer� p� au Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Crude Oil Throughput: Actual Annual Amount (bbl/year) 760,000 Requested Annual Permit Limit4 (bbl /year) 912,500 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 37.6 degrees 0 Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 7.6 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank' Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Crude TKs 12 4,800 March 2018 March 2018 API Number Wells Serviced by this Storage Tank or Tank-Battery5 (EftP Sites Only) Name of Well Newly Reported Well See attached well list (Addendum) O 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EFtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude` or UTM) 40.259953 / -104.320403 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity {ft/sec) ECD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) El Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Q Circular O Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 84 Interior stack width (inches): Interior stack depth (inches): Form APCD-210 - Crude Oft Storage Tank(s) APEN - Revision 07/2017 COLORADO 3 I °`TM"esnce`runuc Fi5Wri. �!M1lmn!sM Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: Cimarron Big Hurt Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: El Yes 0 No Pilot Burner Rating: 2,186.83 Btu/scf MMBtu/hr 0.2 O Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 8.9 Describe the separation process between the well and the storage tanks: psig Wells flow to 3 -phase separators to heater treater to VRT to storage tanks Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 �j iCOI. ORADO S_l o`�.nno-`eee a[+�an� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit if and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN forms. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Uncontrolled Basis lb/bbl Eng. est. 279.76 13.99 Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 0.7362 335.90 16.80 NOx 0.068 lb/MMBtu AP -42 0.52 0.61 CO 0.31 Ib/MMBtu AP -42 2.37 2.79 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factors Actual Annual Emissions Uncontr oiled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions (Pounds/year) Benzene 71432 0.0018 lb/bbl Eng. est. 1,334.01 66.70 Toluene 108883 0.0010 lb/bbl Eng. est 742.56 37.13 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0141 lb/bbl Eng. est 10,700.20 535.01 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 'COLORADO Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 5 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. \AA oj Signature of Legally Authorized Person (not a vendor or consultant) Marsha Sonderfan Date EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: p✓ Draft permit prior to issuance 2 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 $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 6I 'COLORADO n.c..raw �nu; �+w� o- wok E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: HighPoint Operating Corporation Source Name: Anschutz Equus Farms 3-62-4 NENE Emissions Source AIRS ID2: N/A (23 / `)Fq E (DD Z. - Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-43463 Anschutz Equus Farms 3-62-4-0801C ■ 05-123-43462 Anschutz Equus Farms 3-62-4-0916C ■ 05-123-43464 Anschutz Equus Farms 3-62-4-2417C ■ 05-123-46020 Anschutz Equus Farms 3-62-4-2532XCN ■ 05-123-43429 Anschutz Equus Farms 3-62-4-2532CS ■ 05-123-43467 Anschutz Equus Farms 3-62-4-4033C ■ 05-123-43428 Anschutz Equus Farms 3-62-4-4148C ■ 05-123-43433 Anschutz Equus Farms 3-62-4-5764CSB ■ 05-123-43434 Anschutz Equus Farms 3-62-4-5764CN ■ 05-123-43437 Anschutz Equus Farms 3-62-4-5649C ■ O O O 0 0 0 O O O O Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 t.ce,-%4 S\ c0\ : Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs wil be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid far 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: 1 1'`i1E03 AIRS ID Number: \�> / I liE' O��--- [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: HighPoint Operating Corporation Anschutz Equus Farms 3-62-4 NENE Site Location: NENE Sec. 4 T3N R62W Mailing Address: (Include Zip Code) 555 17th Street, Suite 3700 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code:. 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: msonderfan@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-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 1 I of Public HealtA E Enfrnnmvnl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. - OR - ▪ MODIFICATION to existing permit (check each box below that applies) O Change in equipment 0 Change company name3 O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 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: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate Storage Tank Battery For new or reconstructed sources, the projected start-up date is: 03/07/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: ❑✓ Exploration a Production (E&P) site / weeks/year / 0 Midstream or Downstream (non EaP) site ✓ Will this equipment be operated in any NAAQS nonattainment area? - l0 Yes • No Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? l0 Yes • No If "yes", identify the stock tank gas -to -oil ratio: 0.0013 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualSI emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 2 I a.117 NRef Naa!ih.6 Ertv!.a:ua Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 520,000 624,000 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 37.6 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 7.6 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Cond. TKs 12 4,800 March 2018 March 2018 Wells Serviced by this Storage Tank or Tank Battery6 (EEtP Sites On y) API Number Name of Well Ill Newly Reported Well See attached well list (Addendum) ■ - ■ - ■ ■ - - ■ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.259953 / -104.320403 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity, (ft/sec) ECD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 84 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 3 1 A- «m=, ks.ur, s crvo-o:�,. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: N/A MMBtu/hr Make/Model: Cimarron Big Hurt 95 98 Waste Gas Heat Content: 2,187 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.20 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E6tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —9.0 psig Describe the separation process between the well and the storage tanks: Wells flow to the 3 -phase inlet separators, to the heater treater, to the VRT, and then to the condensate storage tanks. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 ;COLORADO 4 I AVr' �,� � Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor? Actual Annual Emissions Requested Annual Permit 5 ; Emission Limit(s) Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions 8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.76 lb/bbl Eng. Est. 197.59 ✓ 9.88 / 237.11 / 11.86 / NOx 0.068 lb/MMBtu AP -42 0.38 0.38 ✓' 0.45 '® 0.45 ✓ CO 0.31 Ib/MMBtu AP -42 1.75 1.75 v 2.05 I 2.05 ✓ Non -Criteria Reportable Pollutant Emissions Inventory - Chemical Name Chemical Abstract Service (CAS) Number= Emission Factor7 Actual Annual Emissions, Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled .: Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 0.0018 ✓ lb/bbl Eng. Est. 942 / 47 ✓ Toluene 108883 0.0010 ✓ lb/bbl Eng. Est. 524 ./ 26 ✓ Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0145 / lb/bbl Eng. Est. 7,557 ✓ 378 ✓ 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 5 I hiA • COLORADO L r -,t- : S P:N c F:v.a:rTEEnrsrcrrmrni Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and wilt be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized P son (not a vendor or consultant) Date Marsha Sonderfan Senior EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: (] Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, 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.Rov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 6 I AV aR H!+:!� 6 Fn+i!prmtrA Produced Water Storage Tank(s) APEN - Form APCD-207 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 tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. 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: 1(11VE 3,e' 7 AIRS ID Number: j2.� I9FjE/ 00_3 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz Equus Farms 3-62-4 NENE Site Location: NENE Section 4 T3N R62W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: 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 APCD via e-mail to the address provided. 383414 COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 1 ,'4/, _ c . Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source • Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. - OR - • MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 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: For existing sources, operation began on: Produced Water Tank Battery For new or reconstructed sources, the projected start-up date is: 3/7/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 ❑✓ Exploration Et Production (EEtP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EEtP) site ✓ Will this equipment be operated in any NAAQS nonattainment area? IA Yes ■ No Are Flash Emissions anticipated from these storage tanks? J Yes • No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No • IS Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? El Yes • No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • 4 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • 12 ✓ f ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 ;COLORADO I n au� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/year) Produced Water Throughput: 760,000 912,500 From what year is the actual annual amount? Tank design: ❑ Fixed roof 2018 ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) ` Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) Water TKs 2 800 March 2018 March 2018 Wells Serviced by this Storage Tank or Tank Battery5 (EBP Sites Only) API Number Name of Well Newly Reported Well See attached well list (Addendum) 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EaP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported op this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.259953 / -104.320403 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) . Velocity (ft/sec) ECD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑r Upward ❑ Horizontal ❑ Downward 0 Other (describe): Indicate the stack opening and size: (check one) Circular 0 Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 84 Interior stack width (inches): Interior stack depth (inches): COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information D Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): %- ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: TBD MMBtu/hr Type: ECD Make/Model: Cimarron Big Hurt Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 977.97 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.2 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 193 Describe the separation process between the well and the storage tanks: Produced water from the inlet 3 -phase separators is sent to the storage tanks psig Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 COLORADO AY.Ke=7,'u. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD g NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2018 Pollutant_. VOC Uncontrolled Basis 0.0142 lb/bbl Eng. est. Criteria Pollutant Emissions Inventory Source (AP -42, Mfg. etc) Actual Annual Emissions:! Requested Annual Permit Emission Limit(s)4 Uncontrolled Emissions (Tons/year) 5.38 I. Controlled Emissions7 (Tons/year) 0.27 Uncontrolled Emissions (Tons/year) 6.46 I Controlled Emissions (Tons/year) 0.32 7 NOx 0.068 lb/MMBtu AP -42 0.04 / 0.04 CO 0.31 lb/MMBtu AP -42 0.16 0.19 Chemical Name on -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions7 (Pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4- Trimethylpentane 540841 4 Requested values will become permit limitations. Requested Limit(s) should consider future growth. 6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 5 I COLORADO PulNic 54,111# Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. v Signature of Legally Authorized Per'sbn (not a vendor or consultant) Marsha Sonderfan Date EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: ✓❑ Draft permit prior to issuance ❑� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, 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 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 07/2017 ICOLORADO E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: HighPoint Operating Corporation Source Name: Anschutz Equus Farms 3-62-4 NENE Emissions Source AIRS ID2: N/A Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-43463 Anschutz Equus Farms 3-62-4-0801C ■ 05-123-43462 Anschutz Equus Farms 3-62-4-0916C ■ 05-123-43464 Anschutz Equus Farms 3-62-4-2417C ■ 05-123-46020 Anschutz Equus Farms 3-62-4-2532XCN ■ 05-123-43429 Anschutz Equus Farms 3-62-4-2532CS ■ 05-123-43467 Anschutz Equus Farms 3-62-4-4033C ■ 05-123-43428 Anschutz Equus Farms 3-62-4-4148C ■ 05-123-43433 Anschutz Equus Farms 3-62-4-5764CSB ■ 05-123-43434 Anschutz Equus Farms 3-62-4-5764CN ■ 05-123-43437 Anschutz Equus Farms 3-62-4-5649C ■ O O O • • O O O O Footnotes: ' Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 C‘qerse(1ea S44 A4-1S+cl'A RPMN aotot.Aal" " PNEIJ0( Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and J(ft _'^`% Application for Construction Permit 40i& - 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 Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. 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.Rov/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: ff'iVe:030cfi MRS ID Number: 2S /9 E/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz Equus Farms 3-62-4 NENE Site Location: NENE Section 4 T3N R62W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 E -Mail Address2: CDPHE_Corr@hpres.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Marsha Sonderfan Phone Number: 303-312-8524 lUse 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 APCD via e-mail to the address provided. 383415 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017 COLORADO �"Drpartmertantic Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action 2 NEW permit OR newly -reported emission source 2 Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $250 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 name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR - ▪ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 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: Loadout for Crude Oil Tank Battery For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 3/ 7 /2018 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 2 Yes ❑ No ❑ Yes 2 No ❑ Yes i] No i] Yes ❑ No ❑ Yes 0 No ❑ Yes No ❑ Yes 0 No COLORADO 2 I AV n�pmna,ec�wauc HH?UI . imMvnnlem. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: O Condensate 0 Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded': 912,500 Bbl/yr I Actual Volume Loaded: 760,000 Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: trucks (eg, "rail tank cars" or "tank trucks") If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 52.45 °F True Vapor Pressure Q 3.7882displaced Asia ® 60 °F Molecular weight of vapors 68 Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: Bbl/yr Actual Volume Loaded: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 31 AyCOLORADO DCL LOfAP.aUJC Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.259953 / -104.320403 Operator Stack ID No . Discharge Height `Above Ground Level T_ - (Feet) - ..,:r Temp. (_F) Flow Rate (ACFM) Veloci (ft/sec) . ECD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 84 Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system: Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC, HAPs TBD ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr Make/Model: Cimarron Big Hurt 95 98 Waste Gas Heat Content 2,186.83 Btu/scf Constant Pilot Light: 0 Yes El No Pilot burner Rating 0.2 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 • COLORADO 4 I • HWIl@ltdPoWlc Dom. �,,m.M PM PM Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. 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): Control Equipment Description , Overall Requested Control Efficiency (% reduction in emissions) SOX NO. CO V0C ECD 95 HAPs ECD 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled _Emission: Factor mission Factor Units Emission Factor Source- (AP -42 Mfg. etc) Uncontrolled (Tons/year) Controlleds (Tons/t'ea'r) equested Annual Pe mil _. Emission`Limit(s)- Uncontrolled (Tons/year)` ` Controlled (Tons/year) - SOX NO„ 0.068 Ib/MMBtu AP -42 0.1 0.12 VOC 0.15784 lb/bbl Eng. est. 59.98 3.00 72.01 3.60 CO 0.31 Ib/MMBtu AP -42 0.45 0.54 Benzene 0.00038 lb/bbl Eng. est. 0.14 0.01 0.17 0.01 Toluene Ethylbenzene Xylenes n -Hexane 0.00302 lb/bbl Eng. est. 1.15 0.06 1.38 0.07 2,2,4- Trimethylpentane Other: 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 5I COLORADO Des mined Public Permit Number: AIRS ID Number: [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 GP07, I further certify that this source is and wilt be operated in full compliance with each condition of the applicable General Permit. Signature of Legally Authorized Person (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: • Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 coenoo 6 I .Yw ! Department. Public Men . mvian nmin+. Rtc.ts,itl Slq10\ Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal wilt require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/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: V•O4 u1kq AIRS ID Number: 113 /'f1 E /001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz Equus Farms 3-62-4 NENE Site Location: NENE Sec. 4 T3N R62W Mailing Address: (Include Zip Code) 555 17th Street, Suite 3700 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address': msonderfan@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-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 1 I COLORADO Vr awa:m Eneo-nnmeee Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly -reported emission source ✓❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 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: Loadout for Condensate Storage Tank Battery Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 03/07/2018 Will this equipment be operated in any NAAQS nonattainment area? Yes No p ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • El Does this source load gasoline into transport vehicles? Yes No ■ NI Is this source located at an oil and gas exploration and production site? Yes No O • If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No I p Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ MI Form APCD-2O8 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 2 I AV:d.t COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 624,000 bbl/year Actual Volume Loaded: This product is loaded from tanks at this fad ity into: tank trucks (e.g. "rail tank cars" or "tank trucks") 520,000 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 52.45 °F True Vapor Pressure: 3.7882 Psia @ 60 ° F Molecular weight of displaced vapors: 68 lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 3 I COLORADO H••••.• ---c of Public 1 Fnahly E Ertutro:tne .t Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.259953 / -104.320403 Operator Stack ID No Discharge Height Above = Ground LeveL (feet). ,. Temp {��, Flow,Rate {ACFMti1 Velocity (fUsey ..... ECD TBD TBD TBD TBD 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): ❑ Upward with obstructing raincap Interior stack diameter (inches): 84 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOC and HAPs Rating: TBD Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: N/A °F Waste Gas Heat Content: 2,187 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.20 MMBtu/hr MMBtu/hr Make/Model: Cimarron Big Hurt 95 % ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 4 I COLORADO Fea41T.EEnelrpnmerl Permit Number: AIRS ID Number: [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 overall (or combined) control efficiency (% reduction ): Pollutant = Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC ECD 95 HAPs ECD 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory .w Pollutant 0.07 ✓ 0.08 ✓ - Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) -. Controlled " -- Emissions (tons/year) PM SOX NO. 0.068 Ib/MMBtu AP -42 0.07 CO 0.31 Ib/MMBtu AP -42 0.31 0.31 dr 0.08 0.37 0.37 ✓ VOC 0.15784 lb/bbl Eng. Est. 41.04 ✓ 2.05 ✓ 49.25 2.46 / Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (Cps) Service CAS Number Emission Factor Actual Annual Emissions - Uncontrolled Bans Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) ) Controlled Emissions6 (pounds/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.003. lb/bbl Eng. Est. 1,570 ✓ 79 ✓' 2,2,4- Trimethylpentane 540841 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-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 5 I AV ReUc H aril: E Envl:on:atni Permit Number: AIRS ID Number: [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 GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. J/19uaCt^a- (0 - Signature of Legally Authorized Person (not a vendor or consultant) Date Marsha Sonderfan Senior EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: ID Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-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.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 I Aar COLORADO � Gyu rt_nt of hliL� Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit i All sections of this APEN and application must be completed for both new and existing facilities, pcluding 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 &*; incorrectly or is missing information and requires re -submittal. This APEN is to be used for Natural Gas Venting only. Natural 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. 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: ICI k./6:22 09 AIRS ID Number: / 23 glove/665' [Leave blank unless APCD has already assigned a permit # and AIRS ID] Company equipment Identification: Steffes Flare [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Site Name: HighPoint Operating Corporation Anschutz Equus Farms 3-62-4 NENE Site Location: NENE Section 4 T3N R62W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 E -Mail Address2: CDPHE_Corr@hpres.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Marsha Sonderfan Phone Number: 303-312-8524 1Please 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 APCD via e-mail to the address provided. Form APCD-211 - Natural Gas Venting APEN - Rev 03/2017 483417 COLORADO 1 f1i. m �xao.a v„ Permit Number: AIRS ID Number: [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 name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information +- " s- General description of equipment and purpose: Emergency gas flare used to combust produced gas during compressor downtime or pipeline unavailability. For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: / / 3 / 7 / 2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: T`a`i hours/d‘ �jt.r Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week ❑✓ Yes ❑ Yes weeks/year ❑ No 0 No Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 Q IcOLORADO 4's: c.p.Rrtot PaWc Permit Number: AIRS ID Number: / / [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: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 333 333 SCF/hr Vent Gas Heating Value: 1 186 BTU/SCF Requested: 50 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: 'Z,'-, el 'j VOC (mole %) 12.47 VOC (Weight %) 28.11 Benzene (mole %) 0.0180 Benzene (Weight %) 0.06 Toluene (mole %) 0.0151 Toluene (Weight %) 0.06 Ethylbenzene (mole %) 0.0022 Ethylbenzene (Weight %) 0.01 Xylene (mole %) 0.0056 Xylene (Weight %) 0.03 n -Hexane (mole %) 0.1078 n -Hexane (Weight %) 0.41 2,2,4-Trimethylpentane (mole %) 0 00004 2,2,4-Trimethylpentane (Weight %) 0.0002 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX It n -Hexane, temperature, and pressure) Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO n`v"�` ay... Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.259953 / -104.320403 Operator Stack la o Discharge Height Above Ground Level (Feet) Temp ('F) Flow Rate (ACFM) Velocity_ (ft/sec)' Steffes Flare TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap TBD Section 6 - Control Device Information ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency VRU Downtime or Bypassed Make/Model: 0/0 ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: TBD MMBtu/hr Type: Flare Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: Make/Model: Steffes flare 95 98 0/3 Waste Gas Heat Content 1,186 Btu/scf Constant Pilot Light: ❑ Yes ❑✓ No Pilot burner Rating MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 COLORADO 4 Ill' ° PM Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ≥# and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, please describe the control equipment AND state the overall control efficiency (% reduction): Overall Requested Control Efficiency ; (% reduction in emissions ontrol Equipment Description SOX NOX VOC Flare 95 CO HAPs Flare 95 Other: From what year is the following reported actual annual emissions data? Use the following table to report the criteria pollutant emissions from source: _ Pollutant ..... Un_ controlled Emission Emission . Factor i- Emission Factor Source a -n_ missions RequestedJnnuaCPesmtt E—missrora-Ltmitis�' - Factory Units (aa„43, Mfg. etc) Uncontrolled (Tons/year) ' Control(ed6 (Torts/year) Uncontrolled . (Tons/year) Controlled- (Tons/year)' PM SOx NO. 0.068 lb/MMBtu AP -42 2.02 VOC 16,994.93 lb/MMscf Eng. Est. 424.87 1.1• 3 CO 0.31 lb/MMBtu AP -42 9.19 Benzene 37.02 lb/MMscf Eng. Est. 0.93 0.05 Toluene 36.66 Ib/MMscf Eng. Est. 0.92 0.05 Ethytbenzene 6.08 Ib/MMscf Eng. Est. 0.15 0.01 Xylenes 15.76 lb/MMscf Eng. Est. 0.39 0.02 n -Hexane 244.96 lb/MMscf Eng. Est. 6.12 0.31 2,2,4- Trimethylpentane Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. -3•P`:* OVA COLORADO Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 5 I - 4%7= M. Permit Number: AIRS ID Number: [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. LA-1(0/b1Li) i Signature of Legally Authorized 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: 0✓ 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) Send this form along with $152.90 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 Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017 /y^� (COLORADO 4 #V n`s'7.a.m a` 8/13/2019 State.co.us Executive Branch Mail - Anschutz Equus Farms 3-62-4, 123-9F9E, Draft Permit Comments STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> Anschutz Equus Farms 3-62-4, 123-9F9E, Draft Permit Comments Marsha Sonderfan <msonderfan@hpres.com> To: "Ricci CDPHE, James" <james.ricci@state.co.us> Cc: CDPHE_Corr <CDPHE_Corr@hpres.com>, Peter Knell <pknell@spiritenv.com> Hi James, Please redline the APEN per your notes below. I think the sampling condition is ok as well. Marsha From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Tuesday, August 6, 2019 9:17 AM To: Marsha Sonderfan <msonderfan@hpres.com> Cc: CDPHE_Corr <CDPHE_Corr@hpres.com>; Peter. Knell <pknell@spiritenv.com> Subject: Re: Anschutz Equus Farms 3-62-4, 123-9F9E, Draft Permit Comments Tue, Aug 6, 2019 at 3:22 PM Thanks Marsha. Yea, I understand how that could be problematic for operations. I updated the language as you suggested and attached the latest draft here. I think there four permits are ready to go to public comment now. However, I just need permission to redline the flaring APEN before sending them. • Section 3 - Add 744 hours/year for hours of operation • Section 4 - Add 22.94 Ib/Ib-mol as molecular weight • Section 7 - Round controlled VOC up to 21.3 tpy Thanks, James Ricci Permit Engineer COLORADO Air Pollution Control Division Department of Public Health 6 Environment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 1.44 J.noii nnnnio nn rammil hil/l9i4=cti1774dhRnRviavd=ntR,caarch=alignarmmcniri=mcn-PI,RA1R411! 41Rf5406R:In87Rdsnt=18.simnl=msa-f%3A1641_.. 1/4 Hello