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Home My WebLink About20191468.tiffCOLORADO Department of Public Hearth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 April 8, 2019 Dear Sir or Madam: RECEIVED APR 1 2 2019 WELD COUNTY COMMISSIONERS On April 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for HighPoint Operating Corporation - Anschutz Williams 5-61-27 SWSW. 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 John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Imo- UtVC- Ply\ -e v� c c" p�� M�/ is c6,� l4 117, c1 y Qin 2019-1468 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Anschutz Williams 5-61-27 SWSW - Weld County Notice Period Begins: April 11, 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 Williams 5-61-27 SWSW EEtP Well Pad Site SWSW Sec 27 T5N R61W Weld County The proposed project or activity is as follows: The applicant proposes to permit twelve (12) 400 bbl fixed roof crude oil storage tanks, hydrocarbon liquid loading and separator venting at an existing synthetic minor oil Et gas production facility in the eight -hour (8 -hr) Ozone Control Area of Weld County. The operator requests to control the separator venting during pipeline and/or compressor downtime via 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 made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0802.CP1 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's4analysis 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: Daniel E Williams Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO 1 I AyIkgvatmantofmonl%I m n�+nseru�mnma. Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Daniel Williams Package #: 385185 Received Date: 7/13/2018. Review Start Date: 1/17/2019' Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration & Production Well Pad What industry segment?: Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) El Particulate Matter (PM) Highpoint Operating Corporation 123 9F64 Anschutz Williams 5-61-27 SWSW SWSW quadrant of Section 27, Township 5N, Range 61W Weld County Section 02 - Emissions Units In Permit Application ❑ Quadrant Section Township Range SWSW 27 SN, 61 Ozone (N0x & voc) AIRS Point# Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 004 Crude Oil Tank Crude TKs Yes 18WE0802 1 Yes Permit Initial Issuance 005 Liquid Loading --- Yes 18WE0803 1 Yes Permit Initial Issuance 006 Separator Venting - -- Yes 18WE0804 1 Yes Permit initial Issuance Section 03 - Description of Project HighpointOperating is submitting a permit application for a existing synthetic minor facility in the NAAQS 8 -hour ozone nonattainment area. The first of ten wells began producing on 4/17/18. Section 04- Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greaterthan 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirement 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) No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) J J No NOx CO ✓ VOC PM2.5 PM10 TSP ❑ ❑✓ HAPs CI O Crude Oil Storage Tank(s) Emissions Inventory 004Crude Oil Tank Fadlity AIRS ID: 123 9FB4 004 Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: o. d Twelra (12) e 4o0.bbf fixed roof cr de oil storage tanks: donne<ted via l quid manifold. Emission Control Device E ciosp�jn,,bcsier. Description. Requested Overall VOC & HAP Control Efficiency Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Throughput= Requested Permit Limit Throughput 7 't;'%f79"4,.r Barrels (bbl) per year 95 Actual Crude Oil Throughput While Emissions Controls Operating= Potential to Emit (PTE) Throughput= ,3`,- 3050041 Barmk (bbl) per year Requested Monthly Throughput= 905.004: Barrels (bbl) per year Secondary Emissions- Combustion D () Heat content of waste gas = Volume of waste gas emitted per BBL oflq liquids y "5 produced;i,irr,','2.SS3 Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas muted to combustion device = u/scf /bbl 4,657 MMBTU per year 5,589 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 5,589 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Crude Oil Tfgoughps) (Crude Oil Throughput) linli..4.360E-04 MIME EMMINI 2.027E-04 '®"' IIMMINII®" EMIMINIIIMMEMBVI lerillIEMMEIIIIMEME IMMMEIMININE=IIIMEXEM Pollutant ®'NIMIZEEMMIN 942E-06 Control Device (waste heat combusted) 0.007 0.0680 100 (Crude Oil Throughput) Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Pilot Gas Combustion Emissions Pilot Fuel Use= SAL 1868.6 MMBtu/yr Criteria Pollutants Emissions tpy NOx 0.06 CO 0.29 Crude Oil Tanks Vapors Comb scion Emissions VOC uncontrolled actual emissions= VOC uncontrolled potential emissions = VOC Wt%= Flash Gas MW= Heating Vaue= Actual fuel consumption from crude oil tanks = Potential fuel consumption from crude oil tanks = 0.2271982 119 tpy 142 tpy *From flash liberation analysis Ib/ibmol *Prom flash liberation analysis BTU/scf "Flom flash liberation analysis 6,686 MMBtu/yr 8,023 MMBtu/yr Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) Requested Monthly Limits Controlled (Os/month) VOC PM10 PM2.5 NOx CO 142.4 118.63 5.93 14136 7.12 1209.10 0,0 0.02 0.02 0.02 0.02 3.54 0.0 0.02 0.02 0.02 0.02 3.54 0.34 0.23 0.29 0.34. 0.34 57.13 1.53 333 . 1.33 1,53 1.53 260.44 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) Iibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 395 329 16 395 20 183 153 8 183 9 25 21 1 25 1 52 02 3 62 3 3859 3216 161 3859 193 3 2 0 3 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Regulation 7, Section 0011.0, C.1,C.3 Regulation 7, Section XVII.C.21 Regulation 6, Part A, NIPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8, Part E, MACT Subpart HH (See regulatory applleabiitywoaksheet for detailed analysts) 76863 Barrels (bbl) per month I Nox and CO emissions Include crude oil tanks and pilot gas. Source requires a permit Storage tank is subject to Regulation 7, Section XVII, 0, C.1 & C.3 Storage tank is subject to Regulation 7, Section XVII.C.2 Storage Tank Is not subject to NSPS Kb Storage Tank is not subject to COPS 0000 Storage Tank is not subject to MACT HH 2 of K:\PA\2018\18 W E0302.CP1.xlsm Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factorsto estimate emissions? ., If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a s@e specific emissjons factor based on guidelines in PS Memo 14-03 Does the company use a site specific emission factorto estimate emissions? IF yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the-.a'--- fadlity being permitted?' If no, thepermit will contain an 'Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request s control device efficiency greater than 95% for a flare or combustion device? gg4. 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 conrentration sampling Section 09 - inventory SCC Coding and Emissions Factors AIRS Paint # 004 Process # 01 BCC Code Uncontrolled Emissions Pollutant Factor Control% Unia PM10 0.00 0 b/1,000 gallons crude oil throughput PM2.5 0.00 0 b/1,000 gallons crude oil throughput NOx 0.02 0 6/1,000 gallons crude oil throughput VOC 7.5 95 b/1,000 gallons crude oil throughput CO 0.00 0 b/1,000 gallons crude oil throughput Benzene 0.01 95 6/1,000 gallons crude oil throughput Toluene 0.00 95 b/1,000 gallons crude oil throughput Ethyibenzene 0.00 95 6/1,000 gallons crude oil throughput Xylene 0.00 95 6/1,000 gallons crude oil throughput n -Hexane 0.10 95 b/1,000 gallons crude oil throughput 224TMP 0.00 95 6/1,000 gallons crude oil throughput 3 of 6 K:\PA\2018,48WE0802.CP1.xlsm Crude Oil Storage Tank 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 ll.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil storage tank capacity less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.3)? you have indicated that source Is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolfed emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section ll.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to A2 is yes, is the crude oil storage tank capacity less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7 'Source requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located eta transmission/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this crude oil 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? No Yes 'Storage tank Is subject to Regulation 7, Section XVII, B, C.1 & C.3 Section XVII.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XV11.0.3 - Recordkeeping Requirements 5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. '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 Kb, Standards of Performance far 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 ma (^10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after Iuly 23, 1984? 4. Does the tank meet the definition of "storage vessel"' In 60.111b? 5. Does the storage vessel store a"volatile organic liquid (VOL)"' as defined in 60.1116? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))7; or b. The design capacity is greater than or equal to 151 me [-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPe (60,110b(b))7; or c. The design capacity is greater than or equal to 75 M5 ["472 BBL] but less than 151 ma ("950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPe(60.1106(b))? Storage Tank Is not subjectto. NSPS Kb Subpart A, General Provisions §60.112b- Emissions Control Standards for VOC §60.113b -Testing and Procedures §60.1156- 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 crude oil storage vessel located eta 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 crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August23, 2011 and September18, 2015? 3, Are potential VOCemissions' from the individual storage vessel greater than or equal to 6tdns per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"' per 605430? Yes tiitrada 'Storage Tank Is not subject to NSPS 0000 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 §60.5417 -Control Device Monitoring Requirements [Note: If a storage vessel Is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, R 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 2. Is the store a tank located at an oil and natural gas production facility that meets either of the following criteria: a. facility that processes, upgrades or stores hydrocarbon liquids' (63.760(')(2)); OR b. 1. Is the tank 3. Does theta 4. Does the to 5. Is the tank: 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 ie delivered toe final end user'(63.760(')(3))? Gated at a feclilty that Is major' for HAPs? k meet the definition of "storagevessel' in 63.761? k meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? bject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? orage Tank is not subject to MACT HH ubpert A, General provisions per§63.764 (a) Table 2 63.766- Emissions Control Standards 63.773 -Monitoring 63.774-Recordkeeping 63.775 -Reporting RACT Review RACT review is required If Regulation 7 does not apply AND if the tank is in the non-attalnment area. lithe 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 if contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for anylaw, regulation, or dny 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 sill 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 Qualify 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 then Source Is st Source Is st Storage Tar Continue -' Storage Tar Continue -' Storage Tar COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name HighPoint Operating Corporation 123 9FB4 Anschutz Williams 5-61-27 SWSW History File Edit Date I 1/2512019 Ozone Status ( Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 252.1 13.9 0.0 247.7 1.9 0.0 0.0 0.0 0.0 14.9 13.9 0.0 31.3 1.7 New Facility - No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 252.1 13.9 0.0 247.7 1.9 0.0 0.0 0.0 0.0 14.9 13.9 0.0 31.3 1.7 001 ;7 - Cancelleth ,, ,,,,-t RICEr=:iSRC/Ili NCr166T A - - �. ,"i i � ,l I.,;,,,,,'10,, , g n : is- d.0 Iza . - ,1 ,mi I(F r o W, °i i 190 qII 7, ,00 1i0 , INOVP danc9llatiOn request received 04/27/2018A : r 0 002 GP02 RICE- Doosan/PSI PSI 14.6L 36.3 2.5 61.1 0.5 3.5 2.5 7.0 0.3 003 GP02 RICE - Waukesha L7044GS1 215.8 11.4 186.6 1.4 11.4 11.4 24.3 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 0.3 142.4 1.5 2.3 0.3 7.1 1.5 0.1 New Point 005 18WE0803 Crude Oil Loadout 0.1 71.5 0.6 1.1 0.1 3.6 0.6 0.1 New Point 006 18WE0804 Separator Venting 2.4 608.7 11.0 12.1 2.4 30.4 11.0 0.6 New Point 007 GP08 Produced Water Tanks (2) x 400 -bbl 0.1 11.8 0.2 0.4 0.1 5.9 0.2 0.0 New Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 255.0 848.3 0.0 261.0 17.8 0.0 0.0 0.0 0.0 17.8 60.9 0.0 44.6 2.5 VOC: Syn Minor (PSDINANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor: N -Hex HH: Area 7777: Area Permitted Facility Total 0.0 0.0 0.0 0.0 255.0 848.3 0.0 261.0 17.8 0.0 0.0 0.0 0.0 17.8 60.9 0.0 44.6 2.5 Excludes units exempt from permits/APENs (0) Change in Permitted Emissions 0.0 0.0 0.0 0.0 2.9 47.0 0.0 13.3 Pubcom required Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Pe miffed VOC emissions (point and fug bye) 60.9 Facility is eligible for GP02 because < 90 tpy Project emissions greater than 25 tpy 47.0 Note 2 Page 5 of 6 Printed 4/2/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID 9FB4 Facility Name Anschutz Williams 5-61-27 SWSW Emissions - uncontrolled ( bs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane MeOH 224TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001, Ga€tcelled: r RICE - SRC/IH NG466T °� ` °tt 0.0, 002 GP02 RICE - Doosan/PSI PSI 14.6L 673 92 86 52 18 36 100 0.5 003 GP02 RICE - Waukesha L7044GS1 1622 318 300 180 64 349 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 395 183 25 62 _ 3859 3 2.3 005 16WE0803 Crude Oil Loadout 198 92 12 31 1937 1 1.1 006 18WE0804 Separator Venting 2522 2213 409 1039 17948 5 12.1 007 GP08 Produced Water Tanks (2) x 400 -bbl 235 122 12 26 339 2 0.4 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 1.1 0.2 0.2 1.8 1.3 0.2 0.6 12.1 0.2 0.0 0.0 0.0 17.8 *Total Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane MeOH 224 TMP H2S TOTAL (tpy) 'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001r I,, Cangelled r;iGl ,R10E- ERG/II I N 466T;A _ "=0 WO.101 002 GP02 RICE - Doosan/PSI PSI 14.6L 162 91.6 86.3 52 18 36 100 0.3 003 GP02 RICE - Waukesha L7044GSI 1622 318 300 180 64 349 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 20 9 1 3 193 0 0.1 005 18W50803 Crude Oil Loadout 10 5 1 2 97 0 0.1 006 18WE0804 Separator Venting 126 111 20 52 897 0 0.6 007 GP08 Produced Water Tanks (2) x 400 -bbl 12 6 1 1 17 0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.9 0.2 0.2 0.2 0.1 0.0 0.0 0.6 0.2 0.0 0.0 0.0 2.5 6 18WE0802.CP1.xlsm 4/2/2019 of Division h & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0802 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: HighPoint Operating Corporation Anschutz Williams 5-61-27 SWSW 123/9FB4 SWSW SEC 27 T5N R61W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Crude TKs 004 Twelve (12) x 400 -bbl fixed roof crude oil storage tanks connected via liquid manifold Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1 YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, y 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 - COLORADO Air Pollution Control Division Department of Public Health 6 Environment Page 1 of 9 f th ce as r per s. Failure to demonstrate compliance within 180 ermit. A self certification form and guidance on uired by this permit may be obtained online at lf-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: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Crude TKs 004 --- --- 7.1 1.5 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. 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.) COLORADO Air Pollution Control Division Department of Public Health Er Envi+nnmortt Page 2 of 9 E �, i • �� t I 01 Control Device Pollutants Controlled Crude TKs 004 Enclosed Flare 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 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit Crude TKs 004 Crude Oil throughput 905,004 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 9. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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.17; 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. COLORADO Air Pollution Control Division Department of Public Health Er Environment Page 3 of 9 12. it is subject to the emission control requirements II.C.1. The owner or operator shall install and nt that achieves an average hydrocarbon control ice 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. 13. 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 14. 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 the OEtM 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 15. 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 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. 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: COPHE 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 (NO.) 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 COLORADO Air Pollution Control Division Department of Public Health 8 Environment Page 4 of 9 er year or more, a change in actual emissions of ar or more, whichever is less, above the level itted; 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. 18. 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). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. COLORADO Air Pollution Control Division Department of Pubic Health b Environtr4nc Page 5 of 9 22. bUnle� si ally a ed • i �f ise "the general and specific conditions contained in the APCD to be necessary to assure compliance .5(7)(a), C.R.S. 23. a e di •' is pis 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Daniel E Williams Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation COLORADO Air Pollution Control Division Department of Pub[.c Health b Environment Page 6 of 9 Notes ;; • Pe ' it °l . -rat .Q t,tim- '� , his p mit issuance: 1) T .' �a is r qui -d tt. p fee or the processing time for this permit. An invoice fo the, fe �l ba iss er the -rmit is issued. The permit holder shall pay the iwi "'°"31`•':°` oof t �voice. 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) 004 Benzene 71432 395 20 Toluene 108883 183 9 Ethylbenzene 100414 25 1 Xylenes 1330207 62 3 n -Hexane 110543 3859 193 2,2,4- Trimethylpentane 540841 3 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. COLORADO Air Pollution Control Division Department of Puble Health f, Envirenfnent Page 7 of 9 it are based on the following emission factors: CAS # Pollutant U rolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 4.199 E-05 4.199 E-05 AP -42 CO 1.914 E-03 1.914 E-03 AP -42 VOC 3.146 E-01 1.573 E-02 Site Specific 71432 Benzene 4.360 E-04 2.180E-05 Site Specific 108883 Toluene 2.027 E-04 1.014E-05 Site Specific 100414 Ethylbenzene 2.720 E-05 1.360E-06 Site Specific 1330207 Xylene 6.885 E-05 3.442E-06 Site Specific 110543 n -Hexane 4.264 E-03 2.132E-04 Site Specific 540841 2'2'4-2.975 Trimethylpentane E-06 1.487E-07 Site Specific Note: The controlled emissions factors for this point are based on the enclosed combustor 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 PSD or NANSR Synthetic Minor Source of: VOC, NOx, CO MACT HH Major Source Requirements: Not Applicable Area Source Requirements: 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 NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I COLORADO Air Pollution Control Division Departnnni of f+ublc Health & Environment Page 8 of 9 art : • al E i ,pion dard or Hazardous Air Pollutants for Source ateg •- CT r 3. ' ,63. ' 99 Subp•. A - Subpart Z .6.v-." .11 . - Sub • • 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 COLORADO Air Pollution Control Division Department o; PublicHealth Et Environment Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Daniel Williams 385185 7/13/2018 1/17/2014 Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: ':'Exploration & Production Well Pad What industry segment?Oil& Natural Gas Production &Processing - Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Carbon Monoxide (CO) ❑ Particulate Matter (PM) Highpoi nt Operating Corporation Anschutz Williams 5.61-27 SWSW SVV50/ quadrant of Section 27, Township 5N, Range 61W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range SWSW 27 SN 2 Ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 004 Crude Oil Tank Crude TKs. You 18WE0802 1 Yes Permit Initial - Issuance 005 Liquid Loading - --- Yes - 18WE0803, 1 Yes ...Permit Initial Issuance 006 ,. .,,. .. Separator Venting - - ---' .. Yes 18W€0804 ;. 1 Yes Permit Initial Issuance. Section 03 - Description of Project Highpoint Operating is submitting a permit applica producing on 4/17/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area a existing synthetic minor facility in the NAAQS 8 -hour ozone nonattainment area. The first of ten wells began Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? Pits 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) No Yes 502 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) J J J J No NOx CO J VOC PM2.5 PM10 TSP ❑ HAPs LI ID Hydrocarbon Loadout Emissions Inventory 005 Liquid Loading (Facility AIRS ID: 123 9FB4 005 rn County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Crude Oil storage tank loadout o trucks. Enclosed Combustor_' Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Infrormetion for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded=. Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded = 95 100.0 95.00 754,170 Barrels (bbl) per year 905,004 Barrels (bbl) per year 905,004 Barrels (bhl) per year Actual Volume Loaded While Emissions Controls Operating= Requested Monthly Throughput; 76863 Barrels (bbl) per month 54,17.0',:Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2151.6555 Btu/scf Volume of waste gas emitted per year = 796653 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 being permitted? Loading Loss Equation L = 12.46'5"P'M/T 1,428 MMBTU per year 1,714 MMBTU per year 1,714 MMBTU per year The stabilized hydrocarbon liquid -sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor 0.6 ` ` �2 �c,;,.,, Rr �s Takik P True Vapor Pressure 3.7882 " psiaotOd M Molecular Weight of Vapors 08 ;'=,T;1l Ib/Ib-mol T Liquid Temperature 512:12` :' Rankine L Loading Losses 3.760446102lb/1000 gallons 0.157938736 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.001385979 ;; 0.0002189 lb/bbl Flash liberations analysis Toluene 0.000644359 0.000101769 lb/bbl - Flash liberations analysis Ethylbenzene 8.64548E-05 1.36546E -0S lb/bbl - '' Flashliberations analysis Xylene 0.000218839 ' 3.45631E-0516/bbl - Flash liberations analysis n -Hexane 0.013553145 0.002140567 lb/bbl - : Flash liberations. analysis 224 TMP ' 9.456E-06 : 1.49347E-06 lb/bbl - Flash liberations analysis. Loadout Combustion Emissions VOC uncontrolled actual emissions = VOC uncontrolled potential emissions = VOC Wt%= Flash Gas MW = Heating Vaue = Actual fuel consumption from crude oil tanks = Potential fuel consumption from crude oil tanks = 74.03% 39.135 Ib/Ibmol 2151.66 BTU/scf 59.6 tpy 71.5 tpy 'From flash liberation analysis °From flash liberation analysis °From flash liberation analysis 3,356 MMBtu/yr 4,028 MMBtu/yr Pollutant Control Device Pollutant Hydrocarbon Loadout Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) 2.189E-04 1.018E-04 1.493E-06 Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (Volume Loaded) (waste heat combusted) 0.0075 0.0075 ...0.0006=. ,.:..... 0.0680y, 0.3100 Emission Factor Source Emission Factor Source 2 of 6 iC\PA\2018\181NE0802.CP1.xlsm Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tans/year) (tans/year) (tons/year) (Ibs/month) PM10 0.01 0.01 0.01 0.01 0.01 1 PM2.5 0.01 0.01 0.01 0.01 0.01 1 SOx 0.00 0.00 0.00 0.00 0.00 0 NOx 0.14 0.11 0.11 0.14 - 0.14 23 VOC 71.47 59.56 2.98 71.47 3.57 607 CO 0.62 0.52 0.52 0.62 0.62 106 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (Ihs/year) (lbs/year) (lbs/year) Benzene 198 - 165 8 198 10 Toluene 92 77 4 92 5 Ethylbenzene 12 10 1 12 1 Xylene 31 26 1 31 2 n -Hexane 1937 1614 81 1937 97 224IMP 1 1 0 1 0 Section 06 - Regulators Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section III.D.2,a (See regulatory applicability worksheet for detailed analysis) The loadout must operate with submergedfill and loadout emissions must be routed to flare to satisfy RACT. 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 Ut -Technical Analysis Notes Vapor. pressure and molecular weight are taken from the TaNK5 4.0 model. Those properties are also available from the sample analyses, however the TANKS 4.0 values yield a more danservatve emission factor and are therefore acceptable AIRS Point # 005 Section 09 - Inventory SCC Coding and Emissions Factors Process # 01 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 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred 500 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 Ib/1,000 gallons transferred Benzene 0.01 95 16/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.05 95 -.lb/1,000 gallons transferred. 224 TMP 0.00 95 Ib/1,000 gallons transferred 3 of 6 K:\PA\2018\ 18WE0802.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source's 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, Perth, Section 11.0.1.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)7 3. is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per yea of condensate via splashing 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TP?, NOx greaterthan 10TPY or CO ernislons greater than 1OTPY (Regulation 3, Part B, Section 11.0.3)? '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 ITPY(Regulatlon 3, Part A, Sectionll.D.1.a)? 2. Is the loadoutlocated at an exploration and production site (e.g., well pad) (Regulation 3, Part 0, 5ectlon 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbis per yea of condensate via splashllllg 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPr, NOx greater than 5 TPYor CO emissions greater than 10 7P (Regulation 3, Part 0, Section 11.0.21? 'Source requires a permi 7. RACE- Are uncontrolled VOCemisslons from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section 111.D.2.a)? 'The loadout must operate with submerged fill and loadout emissions must be routed to are t satisfy RACr. Disclaimer This document assists operators with determining applicability of certain requiremeats of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. la the event of any conflict between the language of this document and the language of the Clean Air Acl, its implementing regulations, and Air Quality Control Commission regulators, 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 'musY'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 Go to next, Go to the n Go to next Go to next Go to next The loadou The loadou COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name HighPoint Operating Corporation 123 9Ft34 Anschutz Williams 5-61-27 SWSW History File Edit Date 1/25/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons per year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 252.1 13.9 0.0 247.7 1.9 0.0 0.0 0.0 0.0 14.9 13.9 0.0 31.3 1.7 New Facility- No Previous Total Previous Permitted Facili total 0.0 0.0 0.0 0.0 252.1 13.9 0.0 247.7 1.9 0.0 0.0 0.0 0.0 14.9 13.9 0.0 31.3 1.7 Ob'f -= Cancelled ' 2' RICE 148RIOVIH NG456T AVIV -,,IN-S- '° !. P, IS., L iVa, _• � -s-..` , -- . " 0;07., i(lhaia a ijil ,f,1 ^ia'nlHilI,, Z,...:7,:,41,,._ »r v:I a :k°uO.D% d Cancellation request reeeived=04/27/2018 iti ; FI- 002 GP02 RICE- Doosan/PSI PSI 14.6L 36.3 2.5 61.1 0.5 3.5 2.5 7.0 0.3 003 GP02 RICE- Waukesha L7044GSI 215.8 11.4 186.6 1.4 11.4 11.4 24.3 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 0.3 142.4 1.5 2.3 0.3 7.1 1.5 0.1 New Point 005 18WE0803 Crude Oil Loadout 0.1 71.5 D.6 1.1 0.1 3.6 0.6 0.1 New Point 006 18WE0804 Separator Venting 2.4 608.7 11.0 12.1 2.4 30.4 11.0 0.6 New Point 007 GP08 Produced Water Tanks (2) x 400 -bbl 0.1 11.8 0.2 0.4 0.1 6.9 0.2 0.0 NeW Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 8.0 0.0 0.0 0.0 255.0 848.3 0.0 261.0 17.8 0.0 0.0 0.0 0.0 17.8 60.9 0.0 44.6 2.5 VOC: Syn Minor (PSD/NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor: N -Hex HH: Area 7777: Area Permitted Facility Total 0.0 0.0 0.0 0.0 255.0 848.3 0.0 261.0 17.8 0.0 0.0 0.0 0.0 17.8 60.9 0.0 44.6 2.5 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.0 0.0 0.0 0.0 2.9 47.0 0.0 13.3 Pubcom required Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fug tine) 60.9 Facility is eligible for GP02 because < 90 tpy Project emissions greater than 25 tpy 47.0 Note 2 Page 5 of 6 Printed 4/2/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY- HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID 9FB4 Facility Name Anschutz Williams 5-61-27 SWSW Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 ', Cahcelle ''RICE - SRC/IN"NG466T J4iL," -, P S " 3h ,�� , r �$I( , P IN s, ;0.0- 002 GP02 RICE - Doosan/PSI PSI 14.6L 673 92 86 ' 52 18 36 100 0.5 003 GP02 RICE - Waukesha L7044GS1 1622 318 300 180 64 349 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 395 183 25 62 3859 3 2.3 005 18WE0803 Crude Oil Loadout 198 92 12 31 1937 1 1.1 006 18WE0804 Separator Venting 2522 2213 409 1039 17948 5 12.1 007 GP08 Produced Water Tanks (2) x 400 -bbl 235 122 12 26 339 2 0.4 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 1.1 0.2 0.2 1.8 1.3 0.2 0.6 12.1 0.2 0.0 0.D 0.0 17.8 otal Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 OQ1 ) cancelled ; � r' , � RICA -SRC/IH� NG466T A v � �l P 0.0 002 GP02 RICE - Doosan/PSI PSI 14.6L 162 91.6 86.3 52 18 36 100 0.3 003 GP02 RICE - Waukesha L7044GSI 1622 318 300 180 64 349 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 20 9 1 3 193 0 0.1 005 18WE0803 Crude Oil Loadout 10 5 1 2 97 0 0.1 006 18WE0804 Separator Venting 126 111 20 52 897 0 0.6 007 GP08 Produced Water Tanks (2) x 400 -bbl 12 6 1 1 17 0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.9 0.2 0.2 0.2 0.1 0.0 0.0 0.6 0.2 0.0 0.0 0.0 2.5 6 18WE0802.CP1.xlsm 4/2/2019 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0803 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 HighPoint Operating Corporation Anschutz Williams 5-61-27 SWSW 123/9FB4 SWSW SEC 27 T5N R61 W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description --- 005 Truck loadout of crude oil by submerged fill using vapor balance system 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, II 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 COLORADO Air Pollution Control Division Department of Public Health & „nseranment Page 1 of 1 days may result in revoca n of p. m A se - icati f rm an r. guidance on how to self -certify comp = n re• $ re• t s per ;fit m be obtai -d online at www.colorado.gov/cdphe air -permit -se -certi ication. ('egu ation 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 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: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO --- 005 --- --- 3.6 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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 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.) COLORADO Air Pollution Control Division 'Department of PAU4 Health a Environment Page 2 of 2 Facility E ui ment q P ID AIRS Point ° ntr•_ a Po tants Co rolled --- 005 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. 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 Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit --- 005 Crude Oil Loaded 905,004 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 8. 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.) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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) 11. 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. 12. 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): COLORADO Mr Pollution Control Division Department of public Health 6 Environment Page 3 of 3 a. The owner or ope `tor sh �.Il i •e�` ; onsi• . 'ng a ip ent t ' ensure that hoses, couplings, pad - es asp ms tai ed to 'rev . t drippin leaking, or other liquid or vapor oss during owing and un oading. 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. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. 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. 13. 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 &t MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. COLORADO Air Pollution Control Division Department of Pubf o Health 6 Environment Page 4 of 4 Periodic Testing Reiiuirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. 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. 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. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS COLORADO Air Pollution Control Division Department of Public Health 8 Environment Page 5 of 5 19. This permit and any attatable r inspection upon request. The permit w ow =,-r b he APCD . rovided in AQCC Regulation Number , art B, Section II.. upon a request or trans er o ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: COLORADO Air Pollution Control Division Department of Public Health b Environment Page 6 of 6 Daniel E Williams Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation DPHE COLORADO Air Pollution Control Division De'.artmeru of Public Health b Environment Page 7 of 7 Notes to Permit Holder at the ti 1) The permit holder is require ees hesin his peAn 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) 005 Benzene 71432 198 10 Toluene 108883 92 5 Ethylbenzene 100414 12 1 Xylenes 1330207 31 2 n -Hexane 110543 1937 97 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. COLORADO Air Pollution Control Division OepArtmant of Public Health b Environment Page 8 of 8 5) The emission levels contain Point 005: per r re ng emfactors: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.288E-04 1.288E-04 AP 42 CO 5.872E-04 5.872E-04 VOC 1.579E-01 7.897E-03 AP 42 Ch. 5.2 Eq. 1 Benzene 71432 2.189E-04 1.094E-05 Flash Liberation Toluene 108883 1.018E-04 5.088E-06 Ethylbenzene 100414 1.365E-05 6.827E-07 Xylene 1330207 3.456E-05 1.728E-06 n -Hexane 110543 2.141E-03 1.070E-04 2,2,4- Trimethylpentane 540841 1.493E-06 7.467E-08 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) = 3.79 psia M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 512 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors 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 PSD or NANSR Synthetic Minor Source of: VOC, NOx, CO COLORADO Air Pollution Control Division Department of Pubic Health h Environment Page 9 of 9 8) Full text of the Title 40, Prot can be found at the website li http://ecfr.gpoaccess.gov/ Regulations Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Ze'ixes 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 COLORADO Air Pollution Control Division Department of Public Health fa Environment Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Daniel. Williams Package #: :380185 Received Date: 7/13/2018 Review Start Date: ! 1/17/2019 Section 01- Facility Information Company Name• County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: Exploration & Production Well Pad What industry segment?Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) HIghpoint Operating Corpora, 9F84 Anschutz` 1illia ms 5-61-27 SWSW SWSW quadrant of Section 27, Township 5N, Range 61W Weld County Section 02 - Emissions Units In Permit Application Quadrant Section Township Range WSW 27 IN ❑✓ Ozone (NOx 0VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit 9 Issuance # Self Cert Required? Action Engineering Remarks 004 Crude Oil Tank Crude TKs Yes 18WE0802 1 Yes Permit Initial Issuance 005 Liquid Loading --- Yes 18WE0803 1 Yes Permit Initial Issuance 006 Separator Venting - Yes 18WE0804 1 Yes Permit Initial Issuance Section 03 - Description of Project Highpo:nt-Operating is submitting a permit appli. producing on 4/17/18. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? ?Greater than 25 tons per year in Non -Attainment Area. ion for ae isting synthetic minor facility in the NAAQS 8 -hour ozone nonattainment area. The first of ten wells began Section 05 - Ambient Air Impact Analysis Requirement 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 (POD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs sr J Is this stationary source a major source? No If yes, explain what programs and which pollutants here 502 NOx CO Prevention of Significant Deterioration (POD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) L✓ VOC PM2.5 PM10 TSP El El HAPs ❑ ❑ Separator Venting Emissions Inventory 006 Separator Venting Facility AIRs ID: E 123': ' rga;, :,= 9FB41'- County Plant 006 Point Section 02 - Equipment Description Details pressor downtime or pipeline unava Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter '- -. d _- -�• Gas meter --, Section 03 - Processing Rate Information for Emissions Estimates Actual Throughput = 50.0 MMscf per year Requested Permit Unlit Throughput 50:0 MMscf per year Requested Monthly Throughput = 4 MMscf per month ' Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 50 MMscf per year Uncontrolled and controlled emissions 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 'Gas is sent directly to an open fl re from inlet (high pressure) separators during compressor. downtime or pipeline unavailability. During normal operations the gas will he compressed and go to sales. The mas molecular weight are from a representative gas sample that was taken from one of the separators on 6/15/18 at 98 psig and 96 F. 1422.1 Btu/scf scf/bbl MW 25.13 Ib/Ib-mol Displacement Equation Ex=Q*MW*Xx/C Weight Oxygen :'.0.02 CO2 _'.: 4.42 N2 - 0.77 methane : '.41.74 ethane . 16.30 propane '. 19.29 isobutane . 2.53 n -butane -=i'8.01 isopentane 171 n -pentane '. 2 12 cyclopentane 0.18 n -Hexane 0.54 cyclohexane -. 0.13 Other hexanes( 0.95 heptanes 0.43 methylcyclohexane 0.14 224-TMP 0.00 Benzene 0.08 Toluene 0:07 Ethylbenzene ` 0.01 Xylenes 0.03 C8+ Heavies - 0.54 Total voc Wt 100.00 36.76 Pollutant Separator Venting Uncontrolled (lb/MMscf) Controlled (lb/MMscf) 50.44 MIMMII 44.26 InIMMI 0.4089 Pollutant 0.09764 0.004882 Primary Control Device Uncontrolled (Ib/MMBtu) (Waste Heat Comb usted) Uncontrolled lb/MMscf 0.0075 M'¢"'7t 'I Lt 0.0070 .n ! 0.0006. 62 0.0680; 0.3100, V (Gas Throughput) Emission Factor Source Emission Factor Source ractions and 2 of 7 K:\PA\2018\18 W E0802. CP1.xlsm 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 500 VOC CO 0.26 0.26 0.26 0.26 0.26 45 0.26 0.26 0.26 0.26 0.26 45 0.02 0.02 0.02 0.02 0.02 4 2.42 2.42 2.42 2.42 2.42 411 608.71 608.71 30.44 608.71 30.44 5170 11.02 11.02 11.02 11.02 11.02 1872 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 224TMP 2522 2522 126 2522 126 2213 2213 111 2213 111 409 409 20 409 20 1039 1039 52 1039 52 17948 17948 897 17948 897 5 5 0 5 0 Section 86 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicabilityworksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e 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 monied (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 greaterthan 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? Yes 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 greaterthan 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 an 3 of 7 K:\PA\2018\ 18WE0802.CP1.xlsm Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes HPOC is requesting to use an open flare rather than enclosed combustors to control emissions.Under normal operations, the separator gas is routed to a sales pipeline. The open flare will only be used during compressor and/or pipeline downtime. HPOC argues that h wouldrequire fifteen (15) high capacity enclosed combustors to accommodate the potential gas throughput, whereas only one (1) open flare would be,needed. The fifteen (15) combustors would cost $1.13'? million as opposed to $102,000for the open flare, according to analysis provided by HPOC. In addition, HPOC suggests that the additional combustors would result In additional pilot light emissions totalling 1 tpy NOx and 4.5 tpy CO. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 006 Process# SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 10.60 0 lb/MMSCF PM2.5 10.60 0 lb/MMSCF 5Ox 0.84 0 lb/MMSCF NOx .96.70 0 lb/MMSCF VOC 24348.28 95 lb/MMSCF CO 440.84 0 lb/MMSCF Benzene 50.44 95 lb/MMSCF Toluene 44.26 95 lb/MMSCF Ethylbenzene 8.18 95 lb/MMSCF Xylene 20.78 - 95 lb/MMSCF n -Hexane 358.97 95 lb/MMSCF 224 TMP 0.10 95 Ib/MMSCF 4 of 7 K:\PA\2018\ 18WE0802.CP1.xlsm 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, Parte, Section Il.D.1.e)7 2. Are total facilityuncontroiled VOC emissions greater than 5TPY, NOx greater than 30 TPY or CO emissions greater than 30 TPV (Regulation 3, Part B, Section 11.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section 3.0.1.0)? 2. Aretotal facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 0, Section 3.02)7 'Source requires a permit Colorado Regulation 7,Sectlon XVII 1. Was the well newly constructed, hydraulically fractured, orrecompleted on or after August 1,2014? 'Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.a.2— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G -Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that Is not enclosed? 'The control device for this separator is not 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 note rule or regulation, and the analysis A contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the languageeof 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 -mandator 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. ;ill Source Req Source Req Source Is st The control COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name County AIRS ID Plant AIRS ID Facility Name HighPoint Operating Corporation 123 9FB4 Anschutz Williams 5.61-27 SWSW History File Edit Date 1/25/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year EMISSIONS With Controls (tons ner year POINT AIRS ID PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 252.1 13.9 0.0 247.7 1.9 0.0 0.0 0.0 0.0 14.9 13.9 0.0 31.3 1.7 New Facility- No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 252.1 13.9 0.0 247.7 1.9 0.0 0.0 0.0 0.0 14.9 13.9 0.0 31.3 1.7 0017 4^ G"ancelledMI itl ,a RICEv,`SSRC/IH NG466T,P II ice-. T -, dub,i .. , -i,.,,,. „r = -, �` "AN Pnrau ` , t .s 0,0 - _- _, ,. 1A111', , ,. _ _ :- 0:0 . Cancellation request received 04/27/2O18 .. _ 002 GP02 RICE- Doosan/PSI PSI 14.6L 36.3 2.5 61.1 0.5 3.5 2.5 7.0 0.3 003 GP02 RICE- Waukesha L7044GSI 215.8 11.4 186.6 1.4 11.4 11.4 24.3 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 0.3 142.4 1.5 2.3 0.3 7.1 1.5 0.1 New Point 005 18WE0803 Crude Oil Loadout 0.1 71.5 0.6 1.1 0.1 3.6 0.6 0.1 New Point 006 18WE0804 Separator Venting 2.4 608.7 11.0 12.1 2.4 30.4 11.0 0.6 New Point 007 GP08 Produced Water Tanks (2) x 400 -bbl 0.1 11.8 0.2 0.4 0.1 5.9 0.2 0.0 New Point 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.0 0.0 0.0 0.0 255.0 848.3 0.0 261.0 17.8 0.0 0.0 0.0 0.0 17.8 60.9 0.0 44.6 2.5 VOC: Syn Minor (PSDINANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (PSD and OP) HAPS: Syn Minor: N -Hex HH: Area 7777: Area Permitted Facility Total 0.0 0.0 0.0 0.0 255.0 848.3 0.0 261.0 17.8 0.0 0.0 0.0 0.0 17.8 60.9 0.0 44.6 2.5 Excludes units exempt from permits/APENs (A) Chan$e in Permitted Emissions 0.0 0.0 0.0 0.0 2.9 47.0 0.0 13.3 Pubcom required Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fug five) 60.9 Facility is eligible for GP02 because a 90 tpy Project emissions greater than 25 tpy _ 47.0 Note 2 Page 6 of 7 Printed 4/2/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name HighPoint Operating Corporation County AIRS ID 123 Plant AIRS ID 9FB4 Facility Name Anschutz Williams 5-61-27 SWSW Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 Cancelled e RICER SRC/II-I NG466Tf r ,1111 'L tl, ;0 002 GP02 RICE - Doosan/PSI PSI 14.6L 673 92 86 52 18 36 100 0.5 003 GP02 RICE - Waukesha L7044GSI 1622 318 300 180 64 349 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 395 183 25 62 3859 3 2.3 005 18WE0803 Crude Oil Loadout 198 92 12 31 1937 1 1.1 006 18WE0804 Separator Venting 2522 2213 409 1039 17948 5 12.1 007 GPM Produced Water Tanks (2) x 400 -bbl 235 122 12 26 339 2 0.4 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 1.1 0.2 0.2 1.8 1.3 0.2 0.6 12.1 0.2 0.0 0.0 0.0 17.8 otal Reportable = all HAPs where uncontrolled emissions > de minimus values Red Text: uncontrolled emissions < de minimus Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP H2S TOTAL (tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 0027 Cancdllede H`"' RICE SRC/IH,ING466T'A = 16IF,r.,y 10 , , 002 GP02 RICE - Doosan/PSI PSI 14.6L 162 91.6 86.3 52 18 36 100 0.3 003 GP02 RICE - Waukesha L7044GSI 1622 318 300 180 64 349 1.4 004 18WE0802 Crude Oil Tanks (12) x 400 -bbl 20 9 1 3 193 0 0.1 005 18WE0803 Crude Oil Loadout 10 5 1 2 97 0 0.1 006 18WE0804 Separator Venting 126 111 20 52 897 0 0.6 007 GP08 Produced Water Tanks (2) x 400 -bbl 12 6 1 1 17 0 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 0.9 0.2 0.2 0.2 0.1 0.0 0.0 0.6 0.2 0.0 0.0 0.0 2.5 7 18WE0802.CP1.xlsm 4/2/2019 CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE0804 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: General Description: High Point Operating Corporation Anschutz Williams 5-61-27 SWSW 123/9FB4 SWSW SEC 27 T5N R61W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description --- 006 Process gas from ten (10) inlet separators 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, I y 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 COLORADO Air Pollution Control Division Department of Public Health & Environment Page 1 of 9 on. It is - 'er or op responsibi to self- onditions demo ate ompliance Within 180 t in ° •cati •f the rmit. A f certi ara, tion form and • • ante on -certi lian�>> :;, ed b _,-e •• y be obta'• -M • ine 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: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO --- 006 --- 2.4 30.4 11.0 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. COLORADO Air Pollution Control Division Department of Pubfs Health 6 Environment Page 2 of 9 7. e emissio issions co the limit acuity Equipment ID oint of e tabli AIRS Point ble belo s listed i permi e opera' 1 maintain with the educe ssio to less th or equal Numb 3, Part B, Secti III.E.) Control Device Pollutants Controlled 006 Emissions from the separators are routed to an Open Flare during compressor downtime or pipeline unavailability 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 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 Facility Equipment ID AIRS Point Process Parameter Annual Limit --- 001 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. 9. 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 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 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; COPHE COLORADO Air Pollution Control Division Department of P btic Health b Environment Page 3 of 9 installed fo ay 1, 20 be equipwith an r by or b 1, 2016, aft the next ;= bustion n, whi `Fever co -= first. 13. arator co '= =•` .' thi • ubje gs . '• , Section . (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 14. 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 O&tM 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 15. 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 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. 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 COLORADO Air Pollution Control Division Department of Public Health & Environment Page 4 of 9 ite eportabl incre , ,by 50 nor five (ns per ar, whichever is ,,:s, above on - " N su • •` t• ision. • 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. 18. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire COPHE COLORADO Air Pollution Control Division Department of hufrto Health & Environment Page 5 of 9 ce, this ` hall be d enied ab io. This time pri R ertifica . an final auth ration by n (APC F on gro set fo in the Colorad • r Quality and ualit„�..,m o...' ission (AQ . uding failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Daniel E Williams Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation COLORADO Air Pollution control Division Department of Pubic Health b Environment Page 6 of 9 this perm , ce: ay fees f =' e p -ssing ti for his permit n invoice the •,�mit is is -d. Th: ermit holder s i" pay the i in 30 daeip . - voice. • '- .. ` he invoic- - ult 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/agcc-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) --- 006 Benzene 71432 2522 126 Toluene 108883 2213 111 Ethylbenzene 100414 409 20 Xylenes 1330207 1039 52 n -Hexane 110543 17948 897 2,2,4- Trimethylpentane 540841 5 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. COLORADO Air Pollution Control Division Department 0 Public liealth & Environment Page 7 of 9 5) Th P his per on th g emissio ctors: CAS # Pollutant Uncontrolled Emission Factors (lb/MMSCF) Controlled Emission Factors (lb/MMSCF) Source NOx 96.70 96.70 AP -42 CO 440.8 440.8 AP -42 VOC 24348.3 1217.4 Extended Gas Analysis 71432 Benzene 50.44 2.522 108883 Toluene 44.26 2.213 100414 Ethylbenzene 8.178 0.4089 1330207 Xylene 20.78 1.039 110543 n -Hexane 359.0 17.95 540841 2'2'4-0.09764 Trimethylpentane 0.004882 Note: The controlled emissions factors for this point are based on the open flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, N -Hexane PSD or NANSR Synthetic Minor Source of: VOC, NOx, CO 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 COLORADO Air Pollution Control Division Department of N:tbtie Health b Environment Page 8 of 9 MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY 3.59 -63. '' 9 Subpart rt Z Subpar - u rt DDD .`' 200- • . ' rpi • ,y EE - S MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Department of Potato Health & Environrnent Page 9 of 9 ICH 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.gov/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: AIRS NumbelrD . 123 / 9FB4 / b0 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz Williams 5-61-27 SWSW Site Location: SWSW Section 27 T5N R61 W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E Mail Address2: CDPHE_Corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 385180 COLORADO I. lid Permit Number: AIRS ID Number: 123 / 9FB4 / [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 $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 O Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - DI 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: Crude Oil Tank Battery Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 4/17/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 ❑✓ Exploration Et Production (EEtP) site weeks/year 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? FA Yes • No Are Flash Emissions anticipated from these storage tanks? p 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 • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No •- ■ I 'I ;Il "„c TAI Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 2 1 V COLORADO Permit Number: AIRS ID Number: 123 / 9FB4 / [Leave blank unless APCD has already assigned a permit #, and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount. (bbll year) Requested Annual Permit Limits (bbl/year) Crude Oil Throughput: 754,170 905,004 From what year is the actual annual amount? Average API gravity of sales oil: 37 degrees ❑ Internal floating roof 2018 Tank design: ❑✓ Fixed roof RVP of sales oil: 7.3 ❑ 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 April 2018 April 2018 :,:..•.,,:;.�,:,��,_:w�e..z:�a .� Wells Servicedny this_Storage TankTankBatferyr:(EftP-Sites'only)":"7.-:'":-.':_::ar:.:.;;� ' •i.•. 7 •:-.......Name`of Welt: ..``:.. `'..' .. Newly Reported Welt-. .'API Number See attached well list (Addendum) ■ - - ■ - - ■ ■ - - IN 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The MP 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/Congitude or UTM)' 40.366717 / -104.203547 Operator Stack . . ID Nor. 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) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) O Circular Interior stack diameter (inches): 84 ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 3I COLORADO tio«, HRUI, [nvlYanmenl ci Permit Number: AIRS ID Number: 123 I 9FB4 / [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. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 1.13 Type: ECD MMBtu/hr Make/Model: Cimarron Big Hurt Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: Minimum Temperature: 2,151.66 Btu/scf MMBtu/hr 0.21 O Closed Loop System Description of the closed loop system: — El 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)? 6 psig Describe the separation process between the well and the storage tanks: Crude oil from the 3 -phase inlet separators goes to heater treaters, to a VRT and to the storage tanks. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 41 AY COLORADO k°`° ate; il� I IhaI II , Permit Number: AIRS ID Number: 123 / 9FB4 / [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 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) - VOC ECD 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory . _.. ...:_.. -._..-.-:v.-:-....:-__._...';:...EmissionFactor7=---1------ Pollutant ::: ..:.. . _ ...._ ...--._-- _ _- -_-_ ... _ .. .. __ ._._ _.. -- Actual Annual. Emissions ._Requested-Annual.Permit_:.: -- --- tts}s--;:._- mission ' ., :.. Uncontrolled . Basis , _. .. units , S --. Source (AP -42, Mfg.., etc. g ) _ ... - _. Uncontrolled :. Emissions (tons/year) . Controlled ........... 8 .... Emissions (tons/year) Uncontrolled ... _ _ .. Emissions (tons/year) Controlled Emision3 (tons/year) VOC 0.3145 lb/bbl Eng. Est. 118.58 / J 5.93 142.29 7.11 NOx 0.068 lb/MMBtu AP -42 0.29 - 0.34 - CO 0.31 Ib/MMBtu AP -42 1.33, 1.53 - - - -4,.•- ------- Non-Criteria.-Reportable-.PollufanTEniissions_InventaTT-""'..___ �' �hem� Ccah��-��y`-��' Abstract.CAS Service (CAS) Emission Facto 7--.7,. =-:-L- _ --�-_'�."Actua[ AnnuahEinissions:_:�.:_-:.e __......__m:_.__...-_. '- - � - �- .. - Chemical Name _ .._.......-... _..__. ._.. .--...Number i..._—: -. Uncontr olled Basis Basis .__......_. .._ Units ... ... Source (AP -42, ..Mfg., etc.). Uncontrolled Emissions e fPoundsl y ar)_ Controlled. Emissions8 .. (pounds/year)'. Benzene 71432 0.0004 lb/bbl Eng. Est. 328.84 / 16.44 ' Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0043 lb/bbl Eng. Est. 3,214.16 , 160.71 i 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 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. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 5 COLORADO Raft u,ll 1 Permit Number: AIRS ID Number: 123 / 9FB4 / [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. Signature of Legally Authorized P on (not a vendor or consultant) Date1 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 $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-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 6i Alf Oeyarasenr COLORADO ofPIN. N!slUt E €n.lmPmmt lid: I Ilhs„ II' E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: HighPoint Operating Corporation Source Name: Anschutz Williams 5-61-27 SWSW Emissions Source AIRS ID2: 123-9FB4 Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-45729 Anschutz-Williams 5-61-27-4956B ■ 05-123-45727 Anschutz-Williams 5-61-27-6457BN ■ 05-123-45726 Anschutz-Williams 5-61-27-6457BSB • 05-123-45703 Anschutz-Williams 5-61-27-3340B • 05-123-45706 Anschutz-Williams 5-61-27-4841B • 05-123-45715 Anschutz-Williams 5-61-27-3225B • 05-123-45704 Anschutz-Williams 5-61-27-0108BNB • 05-123-45730 Anschutz-Williams 5-61-27-0108BS • 05-123-45708 Anschutz-Williams 5-61-27-1609B III 05-123-45711 Anschutz-Williams 5-61-27-1724B ■ • • ■ - • • • 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 I Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 1411 .�I III 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. 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 (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.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: ( 8 UV 0003 AIRS ID Number: 123 / 9FB4 / 005" [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz Williams 5-61-27 SWSW Site Location: SWSW Section 27 T5N R61W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 385182 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I ANY COLORADO n L„ I Permit Number: AIRS ID Number: 123 I 9FB4 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action El 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) O Change fuel or equipment O Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info 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: Crude Oil Loading Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 04/17/2018 Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ■ No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • 0 Does this source load gasoline into transport vehicles? Yes No ■ 0 Is this source located at an oil and gas exploration and production site? Yes No 0 ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • 0 Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ 0 Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ 0 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2 I AV COLORADO Permit Number: AIRS ID Number: 123 / 9FB4 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑ Condensate ❑✓ Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 905,004 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: tank trucks 754,170 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: 8 Q 3.7882 Psia ® 60 ° F Molecular weight of displaced vapors: 6 Q U 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 7/2018 3 I AV COLORADO Defamonn:M Public H. i4fb€an,rePmM, Permit Number: AIRS ID Number: 123 / 9FB4 / �,v [Leave blank unless APCD has already assigned a permit # and AIRS ID] '5 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.366717 / -104.203547 operator Stack ID NO Discharge Height Above _ . Ground Level (feet) Temp. , (7F) Flow Rate (ACFM) Velocity (ft/sec), ECD TBD TBD TBD TBD indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal 0 Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular ❑ Other (describe): 0 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, HAPs Rating: 0.46 Type: ECD Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: °F Waste Gas Heat Content: MMBtu/hr Make/Model: Cimarron Big Hurt 95 98 0/6 2,151.66 Btu/scf Constant Pilot Light: Yes 0 No Pilot Burner Rating: 0.21 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4I A COLORADO Cay.anbn: vt Rltiic R= 4Uv@govlsv7•msnt il!le Permit Number: AIRS ID Number: 123 / 9FB4 [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 NOx 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 O 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 _ ry..-:.:_ ._�_...::.�.�.-__,...� -- __..._ _. .__ . _ , ; . .. _ ----- -• --- _ _ :; _:.:.... Emission Factor.::.:::` .. . � ., ,_ , w ................... -- •- -- - ------ .. .. . _WH......_ _._...-.._ .._..... - Actual Annual. Emissions_::::::. -- --_ _._.._ .-_ .._. _...._._._ . _..__......,._ w.. Requested Annua _Permit::, ' ;:_ -R.,-::_:._ -: -...--3,:.: - perm...ft.-, �� ..:w� Emission Lirrmt(s),-.4.•.. =,, : :Uncontrolled- - "-c-�: Basis • _ --Units . Source- : • (AP -42', Mfg:; etc.) Uncontrolled `Emissions (tons/yea() Controlled _.., Emissions6::-. (fons%yeai) ' Uncontrolled -. ::" Emmssions:"__. (tons/year) ' _ Controlled -'Emissions` (tons/year) - PM SOX NOx 0.068 Ib/MMBtu AP -42 0.11 . 0.14 --- CO 0.31 Ib/MMBtu AP -42 0.52 .7 0.62 --- VOC 0.15784 lb/bbl Eng. Est. 59.52 - 2.98 — 71.42 3.57 ' Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name .' . Chemical Abstract •_ _.. (CAS) Service CAS Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units _ Source . (AP -42, Mfg., etc.) Uncontrolled . Emissions (pounds/year) Controlled Emissionsb - (pounds year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.00214 lb/bbl Eng. Est. 1,613.3 80.7 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 7/2018 5i COLORADO fi?�rn: of AhElc 4565nv1re,4nrnt VOM Permit Number: AIRS ID Number: 123 / 9FB4 / [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. 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 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $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 COLORADO Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 FA; Gas Venting APEN - Form APCD-211* ;� `tip Air Pollutant Emission Notice (APEN) and Application for Construction Permit <Ni All sections of this APEN and application must be completed for both new and existing facilities, including APEN 9".. updates. An application with missing information may be determined incomplete and may be returned or result in ;I longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: �SWEp18 ,t AIRS ID Number: 123 / 9FB4 / 00,6 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: HighPoint Operating Corporation Anschutz Williams 5-61-27 SWSW SWSW Section 27 T5N R61W Mailing Address: 1099 18th St. Suite 2300 (Include Zip Code) Site Location Weld County: NAICS or SIC Code: 1311 Denver, CO 80202 Contact Person: 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 the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 x8518A, COLORADO Ueparentem Attic ii..Via WMio}1n!M Permit Number: AIRS ID Number: 123 /9FB4/ / [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 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 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: Process gas flare used to combust produced gas during compressor downtime or pipeline unavailability. Company equipment Identification No. (optional): For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 04/17/2018 ❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: 24 Will this equipment be operated in any NAAQS nonattainment area? hours/day 7 Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 days/week 52 weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No 2 IAuiv I q`my mums II Permit Number: AIRS ID Number: 123 / 9FB4 [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 #: # of Pistons: Volume per event: Capacity: gal/min Leak Rate: Scf/hr/pist MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: ,I 295 BTU/SCF Requested: 50 MMSCF/year Actual: 50 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 25.13 VOC (Weight %) 36.76 Benzene (Weight %) 0.08 Toluene (Weight %) 0.07 Ethylbenzene (Weight on 0.01 Xylene (Weight %) 0.03 n -Hexane (Weight %) 0.54 2,2,4-Trimethylpentane (Weight %) 0 000, Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. • Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 I AV COLORADO Mr?ah bEnriremnad. II:It I! .III 'I; i III:, Permit Number: AIRS ID Number: 123 / 9FB4 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical. Coordinates- - (Latitude/Longitude or UTM) 40.366717 / -104.203547 Operator Stack ID No Discharge Height_; Above Ground Leve! - (Feet) Temp . (`F) Flow Rate. (At -FM) Velocity (ft0g-ef Flare 30 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) 0 Circular Other (describe): Interior stack diameter (inches): Upward with obstructing raincap 4 Section 6 - Control Device Information ® Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 7.393 MMBtu/hr Type: Flare Make/Model: Steffes Flare Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 1,295 Btu/scf Constant Pilot Light: O Yes 0✓ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: 0 Form APCD-211 - Gas Venting APEN - Revision 7/2018 lag I,U LC) Ka I)U �P bU s rr,VUrvamrni. Permit Number: AIRS ID Number: 123 / 9F64 [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 Flare 95% HAPs Flare 95% Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant. _a-_...._...._ ..._- . ......... .. Emission Factor Actual Annual Emissions .. Requested Annual Permit, Emission Limit(s)5 . =_ig:FiT..-..- Bases-_= . , . .. .:� _.., Unitr:;_.. - ..:.. ...:...�... :-: Source . - ___(AP_4z, • ..T Mfg::i'etc). .. ..! _.., - :::.Uncontrolled = _:: Emissions- :' � tonsl ear .�: ( Y ) _ _.__ Controlled= Emissions:_ :- tons! ear :i . ( Y )_ :. =Controlled; = -=Uncontrolled: =`=Emissions6:'. _ �,• .'(ton's/t'e`ar).. _-: -: Emissions._ . • ' .(tons/year-J�: PM SOX NO. 0.68 Ib/MMBtu AP -42 2.41.--2726--- l,HZ 2.20- r CO 0.031 Ib/MMBtu AP -42 tl•Q210lrei / 4),•si, 10.04/ VOC 24,348.28 Ib/MMscf Eng. Est. 608.71 / 30.44 r 608.71 i 30.44 Non -Criteria Reportable Pollutant Emissions Inventory Chemical • • Emission Factor . .:: Actual.Annual Emissions.. .. Chemical Name Abstract Uncontrolled, Source Uncontrolled . Controlled Service (CAS) Number. Basis . Units (4P-42, Mfg., etc.) . Emissions (pounds/year) Emissions6 . . (pounds/year) Benzene 71432 50.44 Ib/MMscf Eng. Est. 2,522 / 126 / Toluene • 108883 44.26 Ib/MMscf Eng. Est. 2,213 — 111 Ethylbenzene 100414 8.18 Ib/MMscf Eng. Est. 409 — 20.44 --- Xylene 1330207 20.78 Ib/MMscf Eng. Est. 1,039 - 51.96 '' n -Hexane 110543 358.97 Ib/MMscf Eng. Est. 17,948 - 897 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-211 - Gas Venting APEN - Revision 7/2018 'COLORADO 5 I ANT' ,t h19'ib €++w. t Permit Number: AIRS ID Number: 123 / 9F84 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. Signature of Legally Authorized erson (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: �✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: / /www. Colorado. goy /cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 6IAV Depscromt COLORADO al Pottle x„u�n b F„!loa4l. Hello