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Home My WebLink About20193773.tiffa COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 July 15, 2019 Dear Sir or Madam: RECEIVED JUL 19 2019 WELD COUNTY COMMISSIONERS On July 18, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating, LLC - Kugel 18H -H267. 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 &t 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 P bl iG Rev i cw O 16Vai (9 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director cct PL(Tp), &K(3T), ©c,CJMI, PWC3rhI2Rlerl/aK) gAI/19 2019-3773 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - Kugel 18H -H267 - Weld County Notice Period Begins: July 18, 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: Crestone Peak Resources Operating, LLC Facility: Kugel 18H -H267 Well Production Facility NENE SEC 18 T2N R67W Weld County The proposed project or activity is as follows: The applicant proposes to permit a new oil and gas production facility located in the non -attainment area 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 19WE0379 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ICOLORAOO Department of Public Health 6 Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: CiristopherKester Package #: 395553 Received Date: 4/2/2019 Review Start Date: 5/16/2019 Section 01 - Facility Information Company Name: C-estone Peak Resources Operating LLC County AIRS ID: 123 Quadrant Section Township Range NENE 18 2N 67 Plant AIRS ID: Facility Name: Physical Address/Location: County: Type of Facility: A03O Kugel 18H -H267 NENE quadrant of Section 18, Township 2N, Range 67W Weld County E<ploration & Production Well Pad What industry segment? Cii & Natural Gas Production & P-ocessing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? 1 1 Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point tt Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks Condensate Tank TANKS 19WE0379 ? yes Permit Initial Issuance Produced Water Tank PW 19WE0379 yes Permit Initial Issuance Liquid Loading LOAD-i 19WE0379 yes Permit Initial Issuance r Separator Venting BUFFER 19WE0379 Permit Initial Issuance Fugitive Component Leaks r-UG 19WE0379 Permit Initial Issuance Section 03 - Description of Project New synthetic minor E&P facility in NAA area Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air `mpact Analysis Requirement' Yes Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 502 NOx CO VOC PM2.5 PM10 TSP HAPs (—)11 Colorado Air Permitting Project Is this stationary source a major source? If yes, explain what programs and which pollutants hen SO2 No Prevention of Significant Deterioration (PSD) Title V Operating Permits ;OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.S PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AI Rs ID: 123 County A03D Plant 001 Point Section 02 - Equipment Description Details Detailed Emissions Unit Eight (8) 500 bbl fixed roof condensate storage tanks. Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Enclosed Combustor 9S Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = IRequested Permit Limit Throughout = Potential to Emit (PTE) Condensate Throughput Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 1,533,000 Barrels (bbl) per year Actual Condensate Throughput Whi e Emissions Controls Operating = 1,533,000 Barrels (bbl) per year 1,533,000 Barrels (bbl) per year Requested Monthly Throughput = 130200 Barrels (bbl) per month 1,533,000 Barrels (bbl) per year 3034 12.02 Btu/scf scf/bbl 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 Will this storage tank emit flash emissions? Yes 55,906 MMBTU per year 55,906 MMBTU per year 55,906 MMBTU per year Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Condensate Throughput) (Condensate Throughput) VOC 1.64E+00 8.18E-02 :site Specific E.F. (Includes flash) Benzene 5.79E-03 2.90E-04 Site Specific E.F. (includes fiash) Toluene 6.75E-03 3.38E-04 Site Specific E.F. (includes flash) Ethylbenzene 3.27E-04 1.64E-05 Site Specific ES. (includes flash) Xylene 2.52E-03 1.26E-04 Site Specific ES. (includes flash) Site Specific E.E. (includes flash) Site Specific ES. (includes flash) n -Hexane 6.06E-02 3.03E-03 224 TMP 2.33E-0-1 1.17E-05 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0075 0.0003 AF -42 Table 1.4-2 (PM1O/PM.25) AP -42 Table 1,42 (PM10/PM.2.5) AF -42 Chapter 13.5 Industrial flares (NOx) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0075 0.0003 NOx 0.0680 0.0025 CO 0.3100 0.0113 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Em ssions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOx 1253.2 1253.2 62.7 1253.2 62.66 10644 0.2 0.2 0.2 0.2 0.21 35 0.2 0.2 0.2 0.2 0.21 35 1.9 1.9 1.9 1.9 1.90 323 CO 3.7 8.7 8.7 8.7 8.67 1472 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Em ssions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 8876 8876 444 8876 444 Toluene 10343 10348 517 10348 517 Ethylbenzene 501 501 25 501 25 Xylene 3863 3863 193 3863 193 n -Hexane 92900 92900 4645 92900 4645 224 TMP 357 357 18 357 18 Section 06 - Regulatory Summary Analysis I Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) 3 of 16 K:\PA\2019\19WE0379.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? No If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? No If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines it PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Yes If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a cortrol device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point ft 001 Process # 01 SCC Code 4.04-003-1 ixr:o itclot Tank. Cc:,;?;1,;,�Leiivofkirfg+bteaihing+ffash'sng losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons condensate throughput PM2.5 0.01 0 lb/1,000 gallons condensate throughput NOx 0.06 0 lb/1,000 gallons condensate throughput VOC 38.9 95 lb/1,000 gallons condensate throughput CO 0.27 0 lb/1,000 gallons condensate throughput Benzene 0.14 95 lb/1,000 gallons condensate throughput Toluene 0.16 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput Xylene 0.06 95 lb/1,000 gallons condensate throughput n -Hexane 1.44 95 lb/1,000 gallons condensate throughput 224 TMP 0.01 95 lb/1,000 gallons condensate throughput 4 of 16 K:\PA\2019\19WE0379.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re elation 3 Parts A and B - APF.N and Permit Requirements Source is in the Nom Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You have indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05.01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II D.2)? Source requires a permit No Colorado Regulation 7 Section XII.C-F 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7, Section XII. C -F Section XII.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C2 - Emission Estimation Procedures Section XII.D - Emissions Control Requirements Section XII.E - Monitoring Section XII.F - Recordkeeping and Reporting Colorado Regulation 7 Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section XII.G Yes Yes Yes Yes Yes No Section XII.G2 - Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C2 — Emission Estimation Procedures Colorado Regulation 7 Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or ratural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Storag€ tank is subject to Regulation 7, Section XVII, B. C.1 & C.3 No Yes '1C-1 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - F.ecordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Yet 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 for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m') (`472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ("10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to custody transfers as defined in 60.111b7 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"3 in 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ['29.7 psij and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' h950 BBL) and stores a liquid with a maximum true vapor pressure' less than 35 kPa (60.11ob(b))?; or c. The design capacity is greater than or equal to 75 M3 ['472 88L) but less than 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? Yes Yes Source Req Go to next Source Req Continue -' Continue -' Source is st Continue -' Storage Tar Continue -' Go to then Go to the n Source is st Source is st Go to the n Storage Tai Storage Tank is not subject to NSPS Kb Subpart A, Genera Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart OOOO. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions= from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HI-? Storage Tank Is not subject to NSPS OOOO Ye; No No Subpart A, Genera Provisions per §60.5425 Table 3 4603395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notitication, Reporting and Recordkeeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Contra Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Continue -' a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR Continue -' Storage Tar Storage Tar b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel" in 61761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions -5 per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Storage Tank is not subject to MALT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting RACT Review RACT review is required If Regulation 7 does not apply AND if the tank is In the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This aocument 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 rile or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as "recommend"may." -may." 'should,' and -can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must' and "required' are intended :o describe controlling requirements under the terms of the Clean Air Act and Al Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Storage Tar Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 123 County A03D Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Two (2) 500 bbl fixed roof produced water storage tanks. Enclosed Combustor Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput 1,022,000 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = 1,022,000 Requested Monthly Throughput = 86300 Barrels (bbl) per month I Requested Permit Limit Throughput = 1,022,000 Barrels (bbl) per year Potential to Emit (PTE) Produced Water Throughput = 1,02.2,000 Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 3034 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 3.457 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 10,719 MMBTU per year 10,719 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 10,719 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Produced Water Throughput) (Produced Water Throughput) VOC 2.62E-01 1.31E-02 Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Benzene 7.00E-03 3.50E-04 Toluene 0.00E+00 Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Produced Water State E.F. (includes flash) - Front Produced Water State ES, (includes flash) - Front Produced Water State E.F. (includes Plash) - Fro- Ethylbenzene 0.00E+00 Xylene 0.00E+00 n -Hexane 2.20E-02 1.10E-03 224 TMP 0.00E+00 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) - (waste heat combusted) (Produced Water Throughput) PM10 0.0075 0.0000781 AP -42 Table 1.4-2(PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Chapter 13.5 Industrial Flares (NOx) AP-42,Chapter 133.$ Industrial Flares (CO) PM2.5 0.0075 0.0000781 NOx 0.0680 0.0007132 CO 0.3100 _ 0.0032514 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) VOC 133.9 133.9 6.7 133.9 6.7 1137 P M 10 0.0 0.0 0.0 0.0 0.0 7 PM2.5 0.0 0.0 0.0 0.0 0.0 7 NOx 0.4 0.4 0.4 0.4 0.4 62 CO 1.7 1.7 1.7 1.7 1.7 282 + Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (Ibs/year) Benzene 7154 7154 358 7154 358 Toluene 0 0 0 0 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n -Hexane 22484 22424 1124 22484 1124 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO (See regulatory applicability worksheet for detailed analysis) 6 of 16 K:\PA\2019\19W E0379.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain ar "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes +.Y. q 1 JI IM• t .I .>.:.! "C I :'I<Y t C ! mY k.t.2 --•)-:-..x..- •I I I 1 :.1'..,11...,;,!;,,T.," 1I .( ,.T ! 11 1 t.::.:<7••::!:".-O::/‘YY ry 3 S - I' Li Jte I \ b '�. 1 1' { X:.::::: 'C % % .. ;1 I I 1t)1 .LI lC %\CT%Y J (:..,.1:c ! C j • Ill I .Ii N. :: :II r II 1 _.,�I11�ItM1. ••1�'IvrY�L ,..:•\J,.♦ .n.. 1 1 .'Rl.t: .... �.1.01.";141: . 11 OI X tt l 11 (• F' I 1 'I 1 < I '^ y '1 4% 1 1 V' r: +.. .••.•'1 4.' 1 I'.. 1 I� 1• IY.. l .C::XX. .11•Y ) .C:: x: •I1 I r Tx: hI'T'c111: Y) r'•..� %ri%Y.I:XX'i:V.l,3 <. �I. .'..f '�' :. :..Vn .. <v.. '. • ... Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses it Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 Ib/1,000 gallons liquid throughput NOx 0.02 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.08 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 Ib/1,000 gallons liquid throughput n -Hexane 0.52 95 Ib/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 7 of 16 K:\PA\2019\19WE0379.CP1 Produced Wate- Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable far certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Re ulation 3 Parts A and B - APEN and Permit Re u rements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? You lave indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants frcm this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? No Yes Seur_e requires a permit Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station; or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage talk? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C. 3 Section XVII.B - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. No Yes Yes Yes No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? Yes No Storage Tank is not subject to NSPS OOOO Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Ccver and Closed Vent System Monitoring Requirements §60.5417 - Cont-ol Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] , RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RAG requirements. Disclaimer This document assists operators with deternming applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances_ This document does not change or substitute for any law, regtlation, or any other legally binding requirement and is not legally enforceable. in the event of any conflict between the language of this document and the language of the Clean Air Act,, its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend," 'may" "should. "and 'can." is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to descnbe controlling requirements under the terms of the Clean Air Act and Air Qual.ty Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req Go to next Source Req Continue - Continue -. Go to the n Source is st Source is st Continue - Storage Tar Hydrocarbon Loadout Emissions nventory 003 liquid Loading Facility AIRs ID: 123 County AO3D Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Truck loadout of condensate from tanks Encased combustor 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbcn Loadout Actual Volume Loaded = 1,533,000 Barrels (bbl) per year Requested Permit Limit ThrougF put = Potential to Emit (PTE) Volume Loaded = Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Actual Volume Loaded While Em ssions Controls Operating = 1,533,000 Barrels (bbl) per year 1,533,000 Barrels (bbl) per year Requested Monthly Throughput = 1,533,000 Barrels (bbl) per year 3034 Btu/scf 1404211 scf/year 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*S*P*M/T 4,260 MMBTU per year 4,260 MMBTU per year 4,260 MMBTU per year 130200 Barrels (bbl) per month 1 No A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor 0.6 P True Vapor Pressure 4 psia M Mo ecular Weight of Vapors 54.1 Ib/Ib-mol T Liquid Temperature 519.67 Rankine l Loading Losses 3.113141802 lb/1000 gallons 0.130751956 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.003541056 0.000463 lb/bbl vapor composition of the tank emissions Toluene 0.004129957 0.00054 lb/bbl vapor composition of the tank emissions Ethylbenzene 0.000199615 0.0000261 lb/bbl vapor composition of the tank emissions Xylene 0.00154491 0.000202 lb/bbl vapor composition of the tank emissions n -Hexane 0.037093135 0.00485 lb/bbl vapor composition of the tank emissions 224 TMP 0.000142254 0.0000186 _lb/bbl vapor composition of the tank emissions Emission Factors Hydrocarbon Loadout Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC 1.31E 01 6.51E -U3 :.att Specific- AP -42: Chapter 5.2, Equation I Site Specific - AP -42: Chapter 5.2, Equation I Site Specific- AP -42: Chapter 5.2, Equation 1 Site Specific - AP -42: Chapter 52, Equation 1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific- AP -42: Chapter 5.2, Equation 1 Site Specific.- AP -42: Chapter 5,2, Equation 1 Benzene 4.63E-04 2.32E-05 Toluene 5.40E-04 2.70E-05 Ethylbenzene 2.61E-05 1.31E-06 Xylene 2.02E-04 1.01E-05 n -Hexane 4.85E-03 2.43E-04 224 TMP 1.86E-05 9.30E-07 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.0075 2.07E-05 AP -42 Tai; ie (PN110/PM.2-5) ,i.4-2 AP -42 Table 1.4.2 (PMIO/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13.5 Industrial Flares (NOx'> AP -42 Chapter 13.5 Industrial Fl;---.. ''-' PM2.5 0.0075 2.07E -OS SOx 0.0006 1.63E-06 NOx 0.0680 1.89E-04 CO 0.3100 8.62E-04 9 of 16 K:\PA\2019\19W E0379.CP1 Hydrocarbon Loadout Emissions nventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/manth) PM10 PM2.5 SOx N0x 0.02 C.02 0.02 0.02 0.02 3 0.02 C.02 0.02 0.02 0.02 3 0.00 0.00 0.00 0.00 0.00 0 0.14 0.14 0.14 0.14 0.14 25 V0C 100.22 100.22 5.01 100.22 5.01 851 CO 0.66 0.66 0.66 0.66 0.66 112 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 710 710 35 710 35 Toluene 828 828 41 828 41 Ethylbenzene 40 40 2 40 2 Xylene 310 310 15 310 15 n -Hexane 7435 7435 372 7435 372 224 TMP 29 29 1 29 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT - Regulation 3, Part B, Section lll.D.2.a Tile loadout must operate with submerged fill and loadout emissions must be routed to flare to satisfy RAG. (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 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 S0x 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 3.1 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.01 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 0.12 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 10 of 16 K:\PA\2019\19WE0379.CP1 Hydrocarbon Lcadout Regulatory Analysis Worksheet Colorado Re ulatioa 3 Parts A and B - APEN and Permit Re u rements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout Ic:ated at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.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 bbls per year of condensate via splash fill? 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 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B Section II.D.3)? You nave indicated that source is in the Non -Attainment Area Yes NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.l)? 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 year of condensate via splash fill? 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 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3 Part B, Section II.D.2)? Yes no n.a no yes Source requires a permit 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? yes The ioadout must operate with submerged fiI and loadout emissions must be routed to flare to satisfy RAG. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and dcumstances This document does not change or substitute for any law, regulation, or any other legally binding reqLirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of nDn-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 int ?nded 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 ci tself Go to next Go to the n Go to next Go to next Go to next The loadou The loadou Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: 123 County 4030 Plant 004 Point Section 02 - Equipment Description Details Low pressure separator emissions during VRU downtime. This point does not include emissions from the downstream Vapor Recovery Detailed Emissions Unit Description: Tower. Enclosed Flare Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Thrcughput = 5.85 MMscf per year 95 Meter will be required upon commencement of c peration for this facility that has not yet been constructed. Requested Permit Limit Thrcughput = 5.85 MMscf per year Requested Monthly Throughput = �) MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: Ink 5.85 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 Representative gas sample 2162 Btu/scf MW 38.1726 Weight % Helium 0.0C CO2 1.68 N2 0.85 methane 12.16 ethane 17.27 propane 26.22 isobutane 5.89 n -butane 15.51 isopentane 4.72 n -pentane 5.56 cyclopentane 0.35 n -Hexane 1.89 cyclohexane 0.52 Other hexanes 3.02 heptanes 1.45 methylcyclohexane 0.60 224-TMP 0.00 Benzene 0.21 Toluene 0.24 Ethylbenzene 0.02 Xylenes 0.13 C8+ Heavies 1.55 Total 99.8134 VOC Wt % 67.86 scf/bbl lb/lb mol Displacement Equation Ex = Q * MW * Xx / C Emission Factors Separator Venting Pollutant Uncontrolled Controlled Emission Factor Source (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 6.83E+04 3.42E+03 Extended gas analysis Benzene 2.08E+02 1.04E+01 Extended gas analysis Toluene 2.41E+02 1.21E+01 Extended gas analysis Ethylbenzene 1.58E+01 7.91E-01 Extended gas analysis Xylene 1.26E+02 6.32E+00 Extended gas analysis n -Hexane 1.90E+03 9.50E+01 Extended gas analysis £xtendc3df gas analysis 224 TMP 1.21E+00 6.04E-02 Primary Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) lb/MMscf Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 16.109 AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (PM10/PM.2.5) AP -42 Table 1.4-2 (SOx) AP -42 Chapter 13,5 Industrial Flares (NW) AP -42 Chapter 13.5 Industrial Flares (CO: PM2.5 0.0075 16.109 SOx 0.0006 1.272 NOx 0.0680 147.016 CO 0.3100 670.220 12 of 16 K:\PA\2019\19WE0379.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit L mits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) PM10 PM2.5 SOx NOx VOC CO 0.05 0.05 0.05 0.05 0 05 8 0.05 0.05 0.05 0.05 0 05 8 0.00 0.00 0.00 0.00 0 00 1 0.43 0.43 0.43 0.43 0 43 73 199.90 199.90 10.00 199.90 1C.00 1693 1.96 1.96 1.96 1.96 1 96 333 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit L mits Uncontrolled Controlled (lbs/year) (lbsiyear) Benzene 1217 1217 61 1217 61 Toluene 1411 1411 71 141171 Ethylbenzene 93 93 S 93 5 Xylene 739 739 37 739 =7 n -Hexane 11112 11112 556 11112 556 224 TMP 7 7 0 7 J Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVII.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific g_as sample from the equipment being permittel and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. No -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? No If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the peter 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 sectior 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling You have indicated above that the monitored process parameter is natural gas vented. The following questions do not require an answer. 13 of 16 K:\PA\2019\19WE0379.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 16.11 0 Ib/MMSCF PM2.5 16.11 0 Ib/MMSCF SOx 1.27 0 Ib/MMSCF NOx 147.02 0 Ib/MMSCF VOC 68343.26 95 Ib/MMSCF CO 670.22 0 lb/MMSCF Benzene 208.09 95 lb/MMSCF Toluene 241.12 95 Ib/MMSCF Ethylbenzene 15.81 95 Ib/MMSCF Xylene 126.40 95 Ib/MMSCF n -Hexane 1899,46 95 Ib/MMSCF 224 TMP 1.21 95 Ib/MMSCF 14 of 16 K:\PA\2019\19WE0379.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B Section II.D.3)? Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3 Part B, Section II.D.2)? Yes Yes Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014? y2; Source is subject to Regulation 7, Section XVII.B.2, G Section XVII.B.2 - General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.G - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed? The control device for this separator is 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 not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of n )n -mandatory language such as 'recommend," 'may, " "should, " and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and cf itself Source Req Source Req Source is st The contro 005 Fugitive equipment leaks Regulation 7 Information Operating Hours: 8760 hours/year Emission Factor Source Screening EFs - EPA -453/R-95-017 Table 2-8 Control Efficiency Source: Calculations None Service Component Type Count Emission Factor (kglhr- source) Table 2-4 Table 2-8 Control (%) Pollutant Mass Fraction Emissions (tpy) Reg. 3 Connectors 4939 2.00E-04 1.00E-05 0.0% VOC 0.2767 0.3244969 Flanges 850 3.90E-04 5.70E-06 0.0% Benzene 0.0008 0.0009382 Gas Open -Ended Lines 1736 2.00E-03 1.50E-05 0.0% Toluene 0.0012 0.0014073 Pump Seals Valves 0 1647 2.40E-03 4.50E-03 3.50E-04 2.50E-05 0.0% 0.0% Ethylbenzene Xylenes 0.0001 0.0011 0.0001173 0.00129 Other 0 8.80E-03 1.20E-04 0.0% n -Hexane 0.0059 0.0069192 Connectors 263 7.50E-06 7.50E-06 0.0% VOC 1 0.0585365 Flanges 0 3.90E-07 3.90E-07 0.0% Benzene 0.0028 0.0001639 Heavy Oil Open -Ended Lines 519 1.40E-04 7.20E-06 0.0% Toluene 0.0101 0.0005912 Pump Seals 0 0.00E+00 0.00E+00 0.0% Ethylbenzene 0.0014 8.195E-05 Valves 42 8.40E-06 8.40E-06 0.0% Xylenes 0.0136 0.0007961 Other 0 3.20E-05 3.20E-05 0.0% n -Hexane 0.0288 0.0016859 Connectors 2624 2.10E-04 9.70E-06 0.0% VOC 1 0.6338605 Flanges 956 1.10E-04 2.40E-06 0.0% Benzene 0.0028 0.0017748 Light Oil Open -Ended Lines 670 1.40E-03 1.40E-05 0.0% Toluene 0.0101 0.006402 Pump Seals Valves 1 1474 1.30E-02 2.50E-03 5.10E-04 1.90E-05 0.0% 0.0% Ethylbenzene Xylenes 0.0014 0.0136 0.0008874 0.0086205 Other o 7.50E-03 1.10E-04 0.0% n -Hexane - 0.0288 0.0182552 Connectors 36 1.10E-04 1.00E-05 0.0% VOC 1 0.0047354 Flanges 0 2.90E-06 2.90E-06 0.0% Benzene 0.0028 1.326E-05 Water/Oil Open -Ended Lines 4 2.50E-04 3.50E-06 0.0% Toluene 0.0101 4.763E-05 Pump Seals 0 2.40E-05 2.40E-05 0.0% Ethylbenzene 0.0014 6.63E-06 Valves 12 9.80E-05 9.70E-06 0.0% Xylenes 0.0136 6.44E-05 Other 0 1.40E-02 5.90E-05 0.0% n -Hexane 0.0288 0.0001364 Emissions Summary Table Pollutant Uncontrolled Emissions Controlled Emissions Source VOC 1.02 tpy 1.02 tpy Screenin E Benzene 5.78 lb/yr 5.78 lb/yr Screenin E Toluene 16.90 lb/yr 16.90 lb/yr Screenin E Ethylbenzene 2.19 lb/yr 2.19 lb/yr Screenin E Xylenes 21.54 lb/yr 21.54 lb/yr Screenin E n -Hexane 53.99 lb/yr 53.99 lb/yr Screenin E s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 19WE0379 Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 Crestone Peak Resources Operating, LLC Kugel 18H -H267 123/A03D NENE SEC 18 T2N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TANKS 001 Eight (8) 500 bbl fixed roof condensate storage tanks. Enclosed Combustor PW 002 Two (2) 500 bbl fixed roof produced water storage tanks. Enclosed Combustor LOAD -1 003 Truck loadout of condensate from tanks Enclosed Combustor BUFFER 004 Low pressure separator emissions during VRU downtime. This point does not include emissions from the downstream Vapor Recovery Tower. Enclosed Combustor FUG 005 Fugitive component leak emissions None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. Page 1 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- er t- f -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. Point 004: Upon commencement of operation, the operator shall install a flow meter to monitor and record volumetric flow rate of all natural gas routed to the enclosed combustor(s) from all of the low pressure separators covered by this permit. 6. 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. Page 2 of 15 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado EMISSION LIMITATIONS AND RECORDS 7. 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 PM2.5 NOX VOC CO Emission Type TANKS 001 2.0 62.7 8.7 Point PW 002 6.7 Point LOAD -1 003 5.1 Point BUFFER ' 004 10.0 .0 orn; FUG 005 1.1 Fugitive 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. 8. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 3 of 15 COLORADO Air Pollution Control Division Department of Public Heath & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 9. 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.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TANKS 001 Enclosed Combustor VOC and HAP PW 002 Enclosed Combustor VOC and HAP LOAD -1 003 Enclosed Combustor VOC and HAP BUFFER 004 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. 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 TANKS 001 Condensate Throughput 1,533,000 barrels PW 002 Produced Water Throughput 1,022,000 barrels LOAD -1 003 Condensate Loaded 1,533,000 barrels BUFFER 004 Natural Gas Routed to Combustor 5.85 MMscf 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. 11. Point 004: Upon commencement of operation, 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 Page 4 of 15 COLORADO Air Pollution Control Division Department of Public. Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 12. Point 005: The operator shall calculate actual emissions from this emissions point based on hard component counts for the facility with the most recent gas and liquids analyses, as required in the Compliance Testing and Sampling section of this permit. The operator shall maintain records of the results of component counts and sampling events used to calculate actual emissions and the dates that these counts and events were completed. These records shall be provided to the Division upon request. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. Point 003: 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.) 15. This source is subject to the odor requirements of Regulation Number 2. enforceable) 16. Point 003: 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 an enclosed combustor. (Reference: Regulation 3, Part B, III.D.2) 17. Point 003: 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. (State only 18. Point 003: The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. Page 5 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 19. Point 003: 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): Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. Include devices to prevent the release of vapor from vapor recovery hoses not in use Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. 20. Points 001 Ft 005: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling 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. The operator shall comply with all applicable requirements of Section XII. 21. Point 001: This source is subject to Regulation Number 7, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 22. Points 001, 002, a 004: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of Page 6 of 15 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 23. Points 001 a 002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 24. Points 001 a 002: 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. 25. Point 004: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation fromanynewly constructed, hydraulically fractured,or'----"---1 _i J •l,_ _ and g_s 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. 26. Point 005: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. OPERATING £t MAINTENANCE REQUIREMENTS 27. Points 001 - 004: 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 0&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) 28. Point 005: This point is not required to follow a Division -approved operating and maintenance plan. Page 7 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 29. Points 001 Et 003: Within one hundred and eighty (180) days of commencement of operation, the owner or operator shall complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing shall bein accordance with the guidance contained in PS Memo 05-01. Results of testing shall be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis shall be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 30. Point 004: Within one hundred and eighty (180) days after commencement of operation, the owner/operator shall complete an initial site specific extended gas analysis ("Analysis"), of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4-trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis shall be used to calculate site specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis shall be submitted to the Division as part of the self - certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator shall submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). 31. Point 005: Within one hundred and eighty (180) days of the commencement of operation, the owner or operator shall complete the initial extended gas analysis of gas samples and extended natural gas liquids analysis of liquids that are representative of volatile organic compound (VOC) and hazardous air pollutants (HAP) that may be released as fugitive emissions. These extended gas and liquids analyses shall be used in the compliance demonstration as required in the Emission Limits and Records section of this permit. The operator shall submit the results of the gas and liquids analyses and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 32. Point 005: Within one hundred and eighty (180) days of the commencement of operation, the operator shall complete a hard count of components at the source and establish the number of components that are operated in "heavy liquid service", "light liquid service", "water/oil service" and "gas service". The operator shall submit the results to the Division as part of the self -certification process to ensure compliance with emissions limits. Page 8 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Periodic Testing Requirements 33. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 34. 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 (NO.) in ozone nonattainment areas emitting less than 100 tons of VOC or NO), per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 35. 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. 36. 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 Page 9 of 15 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 37. 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. 38. 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. 39. 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. 40. 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. 41. 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: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC Page 10 of 15 COLORADO Air Pollution Control Division Department of Pubiic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing ail 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) 001 Benzene 71432 8,876 444 Toluene 108883 10,354 518 Ethylbenzene 100414 501 25 Xylenes 1330207 3,867 193 n -Hexane 110543 25,804 1,290 2,2,4- Trimethylpentane 540841 358 18 002 Benzene 71432 7,154 358 n -Hexane 110543 22,484 1,124 003 Benzene 71432 710 58 Toluene 108883 828 73 Xylenes 1330207 310 25 n -Hexane 110543 7,435 372 Page 11 of 15 COLORADO Air Pollution Control Division Department of Public Heath b Environment Dedicated to protecting and improving the health and environment of the people of Colorado Benzene 71432 1217 61 Toluene 108883 1411 71 004 Xylenes 1330207 739 37 n -Hexane 110543 11112 556 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per yea (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 1.64E+00 8.18E-02 Promax 71432 Benzene 5.79E-03 2.90E-04 Promax 108883 Toluene 6.75E-03 3.38E-04 Promax 100414 Ethylbenzene 3.27E-04 1.64E-05' Promax 1330207 Xylene 2.52E-03 1.26E-04 Promax 110543 n -Hexane , 1.68E-02 8.40E-04 Promax 540841 2,2,4- Trimethylpentane 2.33E-04 1.17E-05 Promax Note: The controlled emissions Point 002: actors for this point are based on a control efficiency of 95%. CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 2.62E-01 1.31E-02 CDPHE 71432 Benzene 7.00E-03 3.50E-04 CDPHE 110543 n -Hexane 2.20E-02 1.10E-03 CDPHE Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 12 of 15 COLORADO Air Pollution Control Division Department of Pubic I- atth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.068(lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 1.31E-01 6.54E-03 AP -42 71432 Benzene 4.63E-04 2.32E-05 AP -42 108883 Toluene 5.40E-04 2.70E-05 AP -42 1330207 Xylene 2.02E-04 1.01E-05 AP -42 110543 n -Hexane 4.85E-03 2.43E-04 AP -42 Note: The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 4.0 psia M (vapor molecular weight) = 44.15 lb/lb-mol T (temperature of Liquid loaded) = 520 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. The controlled emissions factors for this point are based on a control efficiency of 95%. Point 004: CAS # Pollutant Uncontrolled Emission Factors lb/MMscf Controlled Emission Factors lb/MMscf Source NOx 0.068 (lb/MMBtu) 0.068 (lb/MMBtu) AP -42 CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP -42 VOC 6.83E+04 3.42E+03 Gas Analysis 71432 Benzene 2.08E+02 1.04E+01 Gas Analysis 108883 Toluene 2.41E+02 1.21E+01 Gas Analysis 1330207 Xylene 1.26E+02 6.32E+00 Gas Analysis 110543 n -Hexane 1.90E+03 9.50E+01 Gas Analysis Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 13 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Point 005: Component Gas Service Heavy Oil Light Oil Water/Oil Service Connectors 4939 263 2624 36 Flanges 850 0 956 0 Open-ended Lines 1736 519 670 4 Pump Seals 0 0 1 0 Valves 1647 42 1474 12 Other* 0 0 0 0 VOC Content (wt. fraction) 0.2767 1 1 1 Benzene Content (wt. fraction) 0.0008 0.0028 0.0028 0.0028 Toluene Content (wt. fraction) 0.0012 0.0101 0.0101 0.0101 Ethylbenzene (wt. fraction) 0.0001 0.0014 0.0014 0.0014 Xylenes Content (wt. fraction) 0.0011 O.0136 0.0136 0.0136 n -hexane Content (wt. fraction) 0.0059 0.0288 0.0288 0.0288 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polish rods and vents TOC Emission Factors (kg/hr-component): Component Gas Service Heavy Oil Light Oil Water/Oil Service' Connectors 1.00E-05 7.50E-06 9.70E-06 1.00E-05 Flanges 5.70E-06 3.90E-07 2.40E-06 2.90E-06 Open-ended Lines 1.50E-05 7.20E-06 1.40E-05 3.50E-06 Pump Seals 3.50E-04 0.00E+00 5.10E-04 2.40E-05 Valves 2.50E-05 8.40E-06 1.90E-05 9.70E-06 Other 1.20E-04 3.20E-05 1.10E-04 5.90E-05 Source: Screening EFs - EPA -453/R-95-017 Table 2-8 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 Page 14 of 15 COLORADO Air Pollution Control Division Department of Pubiic Health& Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 and HAP NANSR Synthetic Minor Source of: VOC 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 Performa nce for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KXKK NSPS Part 60, Appendixes Appendix A Appendix,I Part 63: National Emissi Categories on Standards for Hazardous Air Pollutants for Source MACT 63.1-63.599 Subpart A Subpart Z. MALT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 15 of 15 RECE1V g APR 2 2419 r pCf) Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. 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 condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 1 \ 6 39 C AIRS ID Number:I23 2,3 410.3r100 [Leave blank unless APCD has already assigned a permit 4 and AIRS ID] Section 1 - Administrative Information Company Name1: Site Name: Site Location: Crestone Peak Resources Operating, LLC Kugel 18H -H267 Site Location NENE Section 18, T2N, R67W County: Weld Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.weiner@crestonepr.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 335544 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source El Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 0 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 ❑ Transfer of ownership4 ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be -accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Condensate Storage Tanks TANKS For new or reconstructed sources, the projected start-up date is: 12/01/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: ❑✓ Exploration a Production (MP) site weeks/year 0 Midstream or Downstream (non E&P) site Wilt this equipment be operated in any NAAQS nonattainment area? rA Yes ■ No Are Flash Emissions anticipated from these storage tanks? Q Yes 0 No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? © Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 3,77 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes ❑ No n Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ p Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 21 AT' COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbllyear) Condensate Throughput: From what year is the actual annual amount? Average API gravity of sates oil: 47.1 degrees N/A Requested Annual Permit Limits (bbl/year) Tank design: ❑✓ Fixed roof ❑ Internal floating roof 1,533,000 RVP of sales oil: 8.2 O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TANKS 8 4,000 TBD TBD Welts Serviced by this Storage Tank or Tank Battery6 (MP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 37853 Kugel 1A -18H -H267 l7 05 - 123 - asaso Kugel 1B -18H -H267 Fl 05 -123 - 37846 Kugel 1C -18H -H267 l7 05 - 123 - 37842 Kugel 1D -18H -H267 17 05 - 123 - 37852 Kugel 1E -18H -H267 0 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.14342, -104.92734 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) TANKS Indicate the direction of the stack outlet: (check one) 0 Upward 0 Downward 0 Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) El Circular ❑ Square/rectangle ❑ Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 3 I AY COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit II and AIRS ID] Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: TB D Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 3,034 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.03 MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 3.0 psig Describe the separation process between the well and the storage tanks: Wellhead production to hi/lo separators, bulk gas from separators to sales, bulk water from separators to tanks, bulk condensate from separators to vapor recovery tower (VRT), and then to tanks Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 4 I AV COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it 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 fined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissions8 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 1.635 lb/bbl Promax -- -- 1,253.23 -' 62.66 i NOx 0.068 Ib/MMBtu AP -42 — — -- 1.91 CO 0.31 Ib/MMBtu AP -42 -- -- -- 8.70 i Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions° (Pounds/year) Benzene 71432 5.79E-03 lb/bbl eng. calc Toluene 108883 6.75E-03 Ib/bbl eng. calc Ethylbenzene 100414 3.27E-04 lb/bbl eng. talc Xylene 1330207 2.52E-03 lb/bbl eng. calc n -Hexane 110543 6.06E-02 lb/bbl eng. calc 2,2,4- Trimethylpentane 540841 2.33E-04 Ib/bbt eng. talc 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 1403. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 5JAY COLORADO iaIh t. ter noransr 1 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. GO ,‘ 04/02/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑r 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: 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: Colorado Department of Public Health and Environment https://www.colorado.Rov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 61 COLORADO tk a+. b [n.aor.m.x:. E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Crestone Peak Resources Operating, LLC Source Name: Kugel 18H-11267 Battery (TANKS) Emissions Source AIRS ID2: NA / 12'3 / 403D 3D I oo Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 37850 Kugel 1F -1811-H267 /1 05 - 123 - 37851 Kugel 1G -18H-11267 r 05 -123 - 49486 Kugel 1H -18H -H267 LI 05 -123 - 49482 Kugel 1I -18H-11267 /1 05 -123 - 49483 Kugel 1J -18H-11267 /1 05 -123 - 49485 Kugel 1K -1811-H267 /1 05 -123 - 49484 Kugel 1L-1811-11267 ►/ 05 -123 - 49481 Kugel 1M -1811-H267 0 05 -123 - 49479 Kugel 1N -1811-H267 LI - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 4ai - APEN - TANKS - Wellsite Addendum.docx RECEIVED APR - 2 2019 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.cotorado.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. gGe 1 _I tvco 7q Permit Number: t VS E- eiaA4( AIRS ID Number: .a7.. 3 .es 123 A031)/002. - [Leave blank unless APCD has already assigned a permit d. and AIRS ID] Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Site Location: Site Location NENE Section 18, T2N, R67W County: Weld Mailing Address: (include Zip Code) 10188 East 1-25 Frontage Road NAICS or SIC Code: 1311 Firestone, CO 80504 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.weiner@crestonepr.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 355545 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 1 I A COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 2 - Requested Action ID NEW permit OR newly -reported emission source El Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.5O must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 O Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage Tanks PW For new or reconstructed sources, the projected start-up date is: 12/01/2019 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: 0 Exploration ft Production (E£tP) site weeks/year O Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? i Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ❑ Yes i No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No O Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes p 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 © ■ Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? ❑ Yes No D Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 2 IAV 1#pi WFsh If.atti� N tnvtrvnmxa� Upward O Horizontal Permit Number: AIRS ID Number: / / (Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Produced Water Throughput: Requested Annual Permit Limits (bbl/year) 1,022,000 From what year is the actual annual amount? Tank design: J Fixed roof N/A O Internal floating roof O External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW 2 1000 TBD 12/1/2019 Est. Wells Serviced by this Storage Tank or Tank Battery6 (ESP Sites Only) API Number Name of Well Newly Reported Well 05 -123 -37853 Kugel 1A -18H -H267 O 05 -123 -49480 Kugel 1B -18H -H267 ✓ 05 -123 -37846 Kugel IC -18H -H267 ✓ 05 -123 - 37842 Kugel 1D -18H -H267 IN 05 -123 -37852 Kugel 1E -18H -H267 ✓ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.14342, -104.92734 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) PW Indicate the direction of the stack outlet: (check one) O Downward Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) El Circular Interior stack diameter (inches): ['Square/rectangle Interior stack width (inches): Interior stack depth (inches): ['Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 AWN COLORADO 3l Ntnuth4 Uv:ry ^-� i Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor O Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: TB D Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95 98 % % Waste Gas Heat Content: 3,034 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.03 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 50 psig Describe the separation process between the well and the storage tanks: Wellhead production to hi/lo separators, bulk gas from separators to sales, bulk water from separators to tanks, bulk condensate from separators to vapor recovery tower (VRT), and then to tanks COLORADO Form APCD-207 • Produced Water Storage Tank(s) APEN - Revision 7/2018 4 I ITV,T7 "`'t` f<+il9: %Tsv{tuefinenl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it 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 ficiency /% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) ) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) ( Y� ) Controlled Emissions (tons/year) ( Y ) VOC 0.262 lb/bbl APCD -- -- 133.88 s 6.69 NOx 0.068 Ib/MMetu AP -42 -- -- -- 0.26. - CO 0.31 Ib/MMBtu AP -42 — — — 1.19 - Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) (ptw ye ) Controlled Emissions8 (pounds/year) Benzene 71432 0.007 ib/bbl APCD Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 Ib/bbl APCD 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 COLORADO 5j AV u,.:n� a Tmuemn.w Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. Zk1hl4/02/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: Ei Draft permit prior to issuance ✓� Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 • Produced Water Storage Tank(s) APEN - Revision 7/2018 6 I �' COLORADO E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Crestone Peak Resources Operating, LLC Source Name: Kugel 18H -H267 Battery (PW) Emissions Source AIRS ID2: NA / 123 / AO3D/ 00 Z__ Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 37850 Kugel 1F -18H-11267 r 05 - 123 - 37851 Kugel 1G -18H-11267 /1 05 - 123 - 49486 Kugel 1H -1811-H267 L 05 - 123 - 49482 Kugel 1I -18H -H267 /1 05 - 123 - 49483 Kugel 1J -18H -H267 0 05 - 123 - 49485 Kugel 1K -18H-11267 /1 05 - 123 - 49484 Kugel 1L -18H-11267 ►1 05 -123 - 49481 Kugel 1M -1811-H267 L 05 -123 - 49479 Kugel 1N -1811-H267 r - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 4bi - APEN - PW - Wellsite Addendum.docx RECE1Vl ,D APR -22019 Arta Hydrocarbon Liquid Loading APEN• ilia : F9oy 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.>;ov/cdphe/aocd. 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, tI.C. for revised APEN requirements. pv tI . l Permit Number: AIRS ID Number: 12 6 /A051)Y c03 [Leave blank unless APCD has already assigned a permit ; and AIRS ID) /c: $A1037`1 Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Site Location: NENE Section 18, T2N, R67W Mailing Address: (include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.weiner@crestonepr.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. 395546 Form APCD-208 - Hydrocarbon Liquid Loading APEN • Revision 7/2018 a COLORADO 1 I iY�7 r na,._ Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2 - Requested Action El NEW permit OR newly -reported emission source Q Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. - OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership 0 Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & 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: Truck loadout of condensate from tanks Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 12/01/2019 Will this equipment be operated in any NAAQS nonattainment area? Yes No GI ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • GI Does this source load gasoline into transport vehicles? Yes No ■ IN Is this source located at an oil and gas exploration and production site? Yes No 4 ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No ® ■ Does this source splash fill less than 6750 bbl of condensate per year? Yes No 4 ■ Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 21 AY COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: Condensate O Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1,533,000 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars" or "tank trucks") 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: V 60.0 "F True Vapor Pressure: . 0 Psia C 60 °F Molecular weight of displaced vapors: C A .1 0 J'+ lb/lb-mot 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 ©N COLORADO Ili Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ;I and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.14342, -104.92734 Operator:. Stack ID No Discharge Height Above r ,�a Level (feet) Temp CF) .. Flaw Rate f� M) Velocity x 1; LOAD -1 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): 0 Upward with obstructing raincap 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. 0 Loading occurs using a vapor balance system: Requested Control Efficiency: 9K Q Combustion Device: Used for control of: VOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: °F Waste Gas Heat Content: 3,034 Btu/scf Constant Pilot Light: Yes ❑ No Pilot Burner Rating: 0.03 MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 ® COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it 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 uction)• Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOx NOx CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limits) Uncontrolled BasiMfg., Units Source (AP -42, etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM 50x NOx 0.068 - lb/MMBtu AP -42 -- -- -- 0.20 CO 0.31 ' lb/MMBtu AP -42 — — -- 0.90 VOC 0.107' lb/bbl AP -42 -- — 100.16 - 5.01 - Non -Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Service CASSource ( ) Number Uncontrolled asis Units (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 4.63E-04 r lb/bbl Eng. Est. Toluene 108883 5.40E-04 ' lb/bbl Eng. Est. Ethylbenzene 100414 2.61 E-05 , lb/bbl Eng. Est. Xylene 1330207 2.02E-04 ' lb/bbl Eng. Est. n -Hexane 110543 4.85E-03 - Ib/bbl Eng. Est. 2,2,4- Trimethylpentane 540841 1.86E-05 ' lb/bbl Eng. Est. 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 Ay COLORADO 5I mC1 iie4tistr:n! .t ,1.x,1,-zrY..,,i _..-, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 4/02/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692.3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 ® COLORADO It<a�u� N Tnvl.o Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for 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. e+n�- P�c si9r9d �( e -v Permit Number: .3e1„Iir !xe11IN( / ) F Q53 7,1 AIRS ID Number: 113 /1403 O01 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Site Location: NENE Section 18, T2N, R67W Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Taryn Weiner (303) 774-3908 taryn.weiner@crestonepr.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 wilt require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 395547 Form APCD-211 Gas Venting APEN - Revision 3/2019 �� COLORADO 1 I HcahhS [r.rnonmen� Permit Number: Permit Exempt AIRS ID Number: [Leave blank unless APCD has alreacty assigned a permit 11 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) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit O Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR - • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & 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: low pressure separator venting to enclosed combustor when VRU's are offline Company equipment Identification No. (optional): Buffer For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 12/01/2019 ✓❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Wilt this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 3/2019 days/week weeks/year Yes ❑ Yes Q Yes ❑ No D No ❑ No COLORADO 2 I LV7 M �h rn PSY1 Permit Number: Permit Exempt AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information E Gas/Liquid Separator. ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas 2, BTU/SCF Heating Value: 162 Requested: 5.85 MMSCF/year Actual: — MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 38.17 VOC (Weight %) 67.86 Benzene (Weight %) 0.21 Toluene (Weight %) 0.24 Ethylbenzene (Weight %) 0.02 Xylene (Weight %) 0.13 n -Hexane (Weight %) 1.89 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: j Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and pressure) 5 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 31 AY Wrath Fr r,s- COLORADO Permit Number: Permit Exempt AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit :7 and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.14342, -104.92734 Operator Stack ID No. Discharge Height Above Ground LevellF eet) Temp.. f•+}7 Fkfw Rate,Lp1ociitY {ACF/IU' {ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) O Circular ❑ Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: ❑Combustion Device: Pollutants Controlled: VOC, HAPs Rating: Type: Enclosed Combustor MMBtu/hr Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 TBD Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 2,162 0.03 Btu/scf MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO �e�Vt 4 I r Form APCD-211 - Gas Venting APEN - Revision 3/2019 Permit Number: Permit Exempt AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit If 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 SO, NO, CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NOx 0.068 Ib/MMbtu AP -42 -- -- -- 0.44' CO 0.31 Ib/MMbtu AP -42 -- -- — 2.00' VOC 68.34 Ib/Mscf Eng. Est. -- -- 200.00 -, 10.00 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 0.21 e" Ib/Mscf Eng. Est. Toluene 108883 0.24 ' Ib/Mscf Eng. Est. Ethylbenzene 100414 0.02, Ib/Mscf Eng. Est. Xylene 1330207 0.13 ' Ib/Mscf Eng. Est. n -Hexane 110543 1.90' Ib/Mscf Eng. Est. 2,2,4-540841 Trimethylpentane ylp 0.001 .-Ib/Mscf Eng. Est. 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 3/2019 ®'C' eoLoenoa Permit Number: Permit Exempt AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. -7ft„, w 4/02/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ✓l Draft permit prior to issuance Q 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.cotorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO �Y 6 I N h^-neFFnsnonm: ncli4M�< l 11-0 Fugitive Component Leak Emissions APEN Form APCD-203 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for fugitive component leak emissions only. If your emission source 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: 1 q vJEc77 tGG S/9 atta-ctieot ew.a AIRS ID Number: 123 1463I 00S"- [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Kugel 18H -H267 Site Location: NENE Section 18, T2N, R67W Mailing Address: (include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location Weld County: NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: taryn.weiner@crestonepr.com Taryn Weiner ��aZ ii�t6 fi= (303) 774-3908 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 wilt require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 355545 Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 ®V COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) - OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change process or equipment ❑ Change company name3 O Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) - OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information Company equipment Identification No. (optional): F U G For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 12/01/2019 El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ✓❑ Well Production Facility5 O Natural Gas Compressor Stations ❑ Natural Gas Processing Plants O Other (describe): hours/day days/week weeks/year 5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 Alaw il"=14,177;,1;e= =1h b7;r1rrv+ Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit it and AIRS ID) Section 4 - Regulatory Information What is the date that the equipment commenced construction? TBD Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Will this equipment be located at a stationary source that is considered a O Yes 0✓ No Major Source of Hazardous Air Pollutant (HAP) emissions? Are there wet seal centrifugal compressors or reciprocating compressors 0 Yes O No located at this facility? Is this equipment subject to 40 CFR Part 60, Subpart KKK? O Yes OJ No Is this equipment subject to 40 CFR Part 60, Subpart OOOO? ❑ Yes El No Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? 0 Yes ❑ No Is this equipment subject to 40 CFR Part 63, Subpart HH? O Yes ✓0 No Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑ Yes 0✓ No Is this equipment subject to Colorado Regulation No. 7, Section XVILF? 0✓ Yes O No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ✓0 Yes O No Section 5 - Stream Constituents 0✓ The required representative gas and liquid extended analysis (including BTEX) to support the data below has been attached to this APEN form. Use the following table to report the VOC and HAP weight % content of each applicable stream. Stream VOC Ow %) ( Benzene (wt %) Toluene (wt %) Ethylbenzene (wt %) Xylene (wt %) n -Hexane (wt %) 2,2,4 Trimethylpentane (wt %) Gas 27.67 0.08 0.12 0.01 0.11 0.59 0.001 (or Heavy LOiquid) 100 0.28 1.01 0.14 1.36 2.88 0.03 (or Lightt LOiql uid) 100 0.28 1.01 0.14 1.36 2.88 0.03 Water/Oil 100 0.28 1.01 0.14 1.36 2.88 0.03 Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.14342, -104.92734 Attach a topographic site map showing location Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 3 AV COLORADO Hew.. e llnth)i F efvitul11 uffl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit r7 and AIRS ID] Section 7 - Leak Detection and Repair (LDAR) and Control Information Check the appropriate boxes to identify the LDAR program conducted at this site: ❑ LDAR per 40 CFR Part 60, Subpart KKK ❑ Monthly Monitoring - Control: 88% gas valve, 76% light liquid valve, 68% light liquid pump O Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light liquid pump ▪ LDAR per 40 CFR Part 60, Subpart 0000/0000a O Monthly Monitoring - Control: 96% gas valve, 95% light liquid valve, 88% light liquid pump, 81% connectors ▪ LDAR per Colorado Regulation No. 7, Section XVII.F ❑ Other6: O No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 4 A nATO COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit /1 and AIRS ID] Section 8 - Emission Factor Information Select which emission factors were used to estimate emissions below. If none apply, use the table below to identify the emission factors used to estimate emissions. Include the units related to the emission factor. 0 Table 2-4 was used to estimate emissions'. ✓0 Table 2-8 (< 10,000ppmv) was used to estimate emissions. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: Q✓ Estimated Component Count El Actual Component Count conducted on the following date: Service Equipment Type Connectors Flanges nded Op Lines Pump Seals Valves Other9 Gas Count8 4,939 850 1,736 0 1,647 0 Emission Factor 2.20E-05 1.26E-05 3.31 E-05 5.51 E-05 Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source Heavy Oil (or Heavy Liquid) Count8 263 0 519 -- 42 0 Emission Factor 1.65E-05 1.59E-05 -- 1.85E-05 Units lb/hr/source lb/hr/source -- lb/hr/source Light Oil (or Light Liquid) CountB 2,624 956 670 1 1,474 0 Emission Factor 2.14E-05 5.29E-06 3.09E-05 1.12E-03 4.19E-05 Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source Water/Oil Count8 36 0 4 0 12 0 Emission Factor 2.20E-05 7.72E-06 2.14E-05 units lb/hr/source lb/hr/source lb/hr/source • Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA -453/R- 95-017). B The count shall be the actual or estimated number of components in each type of service that is used to calculate the "Actual Calendar Year Emissions" below. 9 The "Other" equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump seals, or valves. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 5 I ®j�WV COLORADO �,a,w� Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit I+ and AIRS ID) Section 9 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. From what year is the following reported actual annual emissions data? NA Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: Use the data reported in Section 8 to calculate these emissions. Chemical Name CAS Number Actual Annual Emissions Requested �imit(s) nual Permit Emission +1 Uncontrolled (tons/year) Controlled t° (tons/year) Uncontrolled (tons/year) Controlled (tons/year) VOC -- -- 1.02- 1.02 - Does the emissions source have any actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? O Yes Q✓ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name CAS Number Actual Annual Emissions Requested Annual PermitEmission )+1 imit Limit(s)11 Uncontrolled (Ibs/year) Controlled10 (ibs/year) Uncontrolled (lbslyear) Controlled (Ibs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane 540841 Other: 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. ++ Requested values will become permit limitations. Requested limits) should consider future process growth, component count variability, and gas composition variability. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 6 I A® COLORADO nt ;for“ Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit :It and AIRS ID] Section 10 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 7a/11,7,1 Ne4,:,L4„ 4/02/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance ✓l Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/aocd MEW COLORADO Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 Hello