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Home My WebLink About20193978.tiffa COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 November 27, 2019 Dear Sir or Madam: RECEIVED DEC 052019 WELD COUNTY COMMISSIONERS On November 28, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for HighPoint Operating Corporation - Anschutz State 5-62-26_25 SWNW. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 - 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 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 PV b i i C Re AR et J CC".PL(TP) HL(uc), Pt(sn /�R/cK/c►c), 12111/1(1 oGCm') 12/0i/I9 2019 -3978 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Anschutz State 5-62-26_25 SWNW - Weld County Notice Period Begins: November 28, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: HighPoint Operating Corporation Facility: Anschutz State 5-62-26_25 SWNW Well Pad Facility SWNW sec 26 T5N R62W Weld County The proposed project or activity is as follows: Conversion from existing GP permits and backup control device. 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 19WE0837 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: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 (COLORADO Department of Public Health b Envixonmctt Separator Venting Emissions Inventory Section 01 - Administrative Information Facility AIRs ID: 123 County 90F8 Plant 005 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Backup flare during pipeline downtime Open Flare Emission Control Device Description: �d�aix.9i+ru7;ii31iK�Y• Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = 45.0 MMscf per year ............ s��S;".x„d�c��noo��—aac+�-}X`s{•u x'��r-x, raz^— < w -a )e.:t i #�xi 7F: nr Y•: c•,ugc W ! t �..i.=r r :ici tiY.'f.. Requested Permit Limit Throughput = 4`_.0 MMscf per year Requested Monthly Throughput = 4 MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: 45 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 1148 Btu/scf MW Weight % _ Helium CO2 4.40 N2 04.68 methane 40.90 ethane 16.81 propane 18.30 isobutane 2.4S n -butane 7.86 isopentane 1.24 n -pentane 2.3E cyclopentane 0.2C n -Hexane 0.70 cyclohexane 0.1E Other hexanes 1.15 heptanes 0.57 methylcyclohexane 0.20 224-TMP O.cc Benzene 0.10 Toluene 0.10 Ethylbenzene 0.02 Xylenes O.OE, C8+ Heavies 1.03 Total 99.99 VOCWt% 37.19 scf/bbl Ib/Ib-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 24922.4934 1246.1247 Benzene 65.8121 3.2906 Toluene 69.9003 3.4950 Ethylbenzene 13.9398 0.6970 Xylene 43.2939 2.1647 n -Hexane 469.1963 23.4598 224 TMP 0.3351 0.0168 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 0.000 '.P -42 Chaptar 2.3.5 industrial Flares (NOx. .. ,. nr.r• ?'�..» » F -:r ( .r;ElCe (CC) .. ...:- 4444 ;_ 4444 I' PM2.5 0.000 SOx 0.000 NOx 0.0680 98.464 CO 0.3100 448.880 1 of 3 K:\PA\2015\15WE1439.CP3 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 2.22 2.22 2.22 2.22 2.22 376 560.76 560.76 28.04 560.76 28.04 4763 CO 10.10 10.10 10.10 10.10 10.10 1716 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 2962 2962 148 2962 148 Toluene 3146 3146 157 3146 157 Ethylbenzene 627 627 31 627 31 Xylene 1948 1948 97 1948 97 n -Hexane 21114 21114 1056 21114 1056 224 TMP 15 15 1 15 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B #REF! Regulation 7, Section XVII.B, G Source is subject to Regulation 7, Section XVIl.B.2, G Regulation 7, Section XVII.B.2.e The control device for this separator is subject to Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. Nes If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Np -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Yes If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency 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 Von have indicated above that the monitored 'process parameter is natural as vented. The following auestions do not reauire an answer. 2 of 3 K:\PA\2015\15WE1439.CP3 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes -MODIFICATION TO THROUGHPUT AND SSEF Or.T,ii l'. t. I.11:I,litYClin':Afiuxaxa`wxE•'.:".tc cacarr..x::a::1'i tr�r h a J Y u t Y.— t+r t i n F tx! p4' r K n n Y a .+ iu x.�z-r"—'c('•to 'c :...L c I G n :+ = r c cv,u:• i $ t. it t St7 +i{t :-....4.:,-...n.,--za t Ile' i c tcirt =ctmszetrx ',uhxrh!Anpl: nx gri :k-‘="7"- _ '4a' } XY t�r • itc ri x o Y '} �Yx vs'“' t�i. it It toy ltt It�a'iY nit x t x< r Y t x a. t r • 'Fr r, , ,,r i. Y�.Te i! bT tr lt> f: tt >lr •:1 it" x x Ct :t • ."`n,:,j[`z as at rxYkyN (x(4: Utt,t+,�� .a fw x a .: :lfjix; � xx�xtitk i.�x 'x'�iF≤txatk: xx 4:, M;uai nc�� ir:. r !:. 'ts"' tY .mss. .^ xd'.- e'x:�.a.t._ ...,. .._ ..x.... " .. :D . .:_..: -.:..Y x ....b.e..k.ax.t>a. x.,w.: e, -.x . . t f i '":c ai»a-2• ^t r': w..n..r..0 .>t::-.:«.IY ., vt.r:%:-e::_ i 1:1 :.f' F"at:txE.:1�ro:xln�n'xxi?Sx:&(i6'F.nntlun�rtlx..'. r--:r,-r.t..Y•x.s„t.X-.::.x'nY:'a..Y::�t-.Y.H�. 's:�Yi vl:M..x1�4rL_k.lu`Y act:-+¢r�'. yr••7'' 't. ��r ii� ti-.;�l"Yi'Tri�1"f•7�ii'.f 1-x1:)1-" Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 005 Process # SCC Code 01 3-10-001-60 Flares Pollutant PM10 PM2.5 SOx NOx VOC CO Benzene Toluene E:hylbenzene Xylene n -Hexane 224 TMP Uncontrolled Emissions Factor 0.00 0.00 0.00 98.46 24922.49 448.88 65.81 69.90 13.94 43.29 469.20 0.34 Control % Units 0 lb/MMSCF 0 Ib/MMSCF 0 Ib/MMSCF 0 Ib/MMSCF 95 Ib/MMSCF 0 Ib/MMSCF 95 Ib/MMSCF 95 Ib/MMSCF 95 lb/MMSCF 95 Ib/MMSCF 95 Ib/MMSCF 95 lb/MMSCF 3 of 3 K:\PA\2015\15WE1439.CP3 Hydrocarbon Loadout Emissions Inventory Section 01 - Administrative Information !Facility AIRs ID: i County Plant 007 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: HYDROCARBON LIQUID LOAOOt1T VIA TRUCK USING VAPOR CAPTURE/COMBUSTION 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = 652,020 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 652,020 Barrels (bbl) per year Requested Permit Limit Throughput = 782,424 Barrels (bbl) per year Requested Monthly Throughput = 66452 Barrels (bbl) per month 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 = 782,424 Barrels (bbl) per year 2742 Btu/scf 513167 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 1,173 MMBTU per year 1,407 MMBTU per year 1,407 MMBTU per year The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source S Saturation Factor 0.6 f� lyNi�. % :et, ' � 1 F"'>.'°2 .c- tlt� asY r t. ..'• l � � - �.,aa.z � .{ ra a ..,,,, r > # ill : ,( ..� '« . r ., P True Vapor Pressure 2.82 psia M Molecular Weight of Vapors 69 Ib/Ib-mol T Liquid Temperature 511.67 Rankine L Loading Losses 2.843004436 lb/1000 gallons 0.119406186 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.000416 lb/bbl Toluene 0 lb/bbl Ethylbenzene 0 lb/bbl Xylene 0 lb/bbl n -Hexane 0.0016 lb/bbl 224 TMP 0 lb/bbl Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source (Volume Loaded) (Volume Loaded) VOC 1.19E-01 5.97E-03 iet 2Cifc- pP42` Chapter 51, Ec uatfort1 Benzene 4.16E-04 2.08E -OS Toluene 0.00E+00 0.00E+00 Ethylbenzene 0.00E+00 0.00E+00 C. .. s Xylene 0.00E+00 0.00E+00 n -Hexane 1.60E-03 8.00E -0S 224 TMP 0.00E+40 0.00E+00 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0.00E+00 .,.' 1. :.api: i3 iR1':%:;:;`.r fares( .::) PM2.5 0.00E+00 SOx 0.00E+00 NOx 0.0580 1.22E-04 CO 0.3100 5.58E-04• 0.119 4.10E-04 3.60E-03 5.95 E-03 2.05 E-05 1.80E-04 1 of 2 K:\PA\2015\15WE1443.CP2 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.00 0.00 0.00 0.00 0.00 0 0.05 0.04 0.04 0.05 0.05 8 46.71 38.93 1.95 46.71 2.34 397 0.22 0.18 0.18 0.22 0.22 37 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene 325 271 14 325 16 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 n -Hexane 1252 1043 52 1252 63 224 TMP 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B #REF! RACT- Regulation 3, Part B, Section III.D.2.a #REF! (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 Modification to existing permit throughput request. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 007 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 SOx 0.00 0 lb/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 2.8 95 lb/1,000 gallons transferred CO 0.01 0 lb/1,000 gallons transferred Benzene 0.01 95 Ib/1,000 gallons transferred Toluene 0.00 9S 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 0.04 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 2 of 2 K:\PA\2015\15WE1443.CP2 Summary of Preliminary Analysis - NG RICE Company Name High Point Operating Corporation Facility Name Anschutz State 5-62-26_25 SWNW Facility Location SWNW SEC 26 T5N R62W Facility Equipment ID C-16144/1 Permit No. AIRS Review Date Permit Engineer 19WE0837 123/9DF8/008 09/20/2019 Timothy sharp Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Waukesha, Model L7044 GSI, Serial Number C-16144/1, natural gas -fired, turbo -charged, LSRB reciprocating internal combustion engine, site rated at 1680 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control This emission unit is used for natural gas compression. Natural Gas Consumption 80.15 Requested (mmscf/yr) Requested (mmscf/m) 6.81 Fuel Heat Value (btu/scf) 1447 BSCF (Btu/hp-hr) 7881 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) 8760 Permit limits calculated at (hpy) 8760 Uncontrolled Controlled NOx mfr JJJJ VOC JJJJ JJJJ CO mfr JJJJ Formaldehyde mfr 0 SOX AP -42; Table 3.2-3 (7/2000); Natural Gas No Control TSP AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM 10 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control Other Pollutants Describe EF sources - HAPs etc. Describe EF sources - HAPs, etc. Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control NOx 215.8 16.2 215.8 92.5% VOC 11.4 11.4 11.4 0.0% CO 181.7 32.4 181.7 82.1% SOx 0.0 0.0 0.0 0.0% TSP 1.1 1.1 1.1 0.0% PM10 1.1 1.1 1.1 0.0% PM2.5 1.1 1.1 1.1 0.0% Total HAPs* 0.0 0.0 1.5 0.0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minirnus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (lb/yr) HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control Formaldehyde 1622 1622 1622 0.0% Methanol 355 355 355 0.0% Acetaldehyde 324 324 324 0.0% Acrolein 305 305 305 0.0% Benzene I 183 0.0% 1,3 -Butadiene * * 77 0.0% Toluene * * 65 0.0% *Uncontrolled requested and controlled UNCONTROLLED is greater than de requested values are shown only for pollutants where REQUESTED minims Permitting Requirements Ambient Air Impacts Source details is of not modeling required analysis) to model based on Division Guidelines/No NAAQS violations expected (see Public Comment Public Comment Required/Public Comment not required MACT ZZZZ Missing or invalid entry information over 500 HP located at a(n) Area Source Reg Standards 7 XVII.E (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg requirements) 7 XVI.B (Ozone applies? NAA Yes MACT ZZZZ (area source) Is this source engine requirements? subject to MACT ZZZZ area No NSPS JJJJ Is this engine subject to NSPS JJJJ? TBD Note: been JJJJ adopted requriements into are not 6. currently included as permit conditions because the reg has not Reg Comments/Notes Previous permit coverage under GP02 Summary of Preliminary Analysis - NG RICE Company Name Facility Name Facility Location Facility Equipment ID Unit 17 High Point Operating Corporation Anschutz State 5-62-26_25 SWNW SWNW SEC 26 T5N R62W Permit No. AIRS Review Date Permit Engineer 19WE0837 123/9DF8/002 09/20/2019 Timothy sharp Requested Action New permit/newly reported emission Issuance No. 1 Emission Point Description One (1) Doosan, Model D111 TIC, Serial Number EEIOH404252, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 302 horsepower. This engine shall be equipped with a non -selective catalytic reduction (NSCR) system and air -fuel ratio control This emission unit is used for natural gas compression. Natural Gas Consumption Requested (mmscf/yr) 12.80 Requested (mmscf/m) 1.09 Fuel Heat Value (btu/scf) 1447 BSCF (Btu/hp-hr) 7003 Emission Factor Sources Hours of Operation PTE Calculated at (hpy) 8760 Permit limits calculated at (hpy) 8760 Uncontrolled Controlled NOx 0 0 VOC 0 0 CO o 0 Formaldehyde 0.00 0 SOX AP -42; Table 3.2-3 (7/2000); Natural Gas No Control TSP AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM 10 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control PM2.5 AP -42; Table 3.2-3 (7/2000); Natural Gas No Control Other Pollutants Describe EF sources - HAPs etc. Describe EF sources - HAPs, etc. Point Summary of Criteria Emissions (tpy) Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control NOx 20.5 2.9 20.5 86.0% VOC 2.0 2.0 2.0 0.0% CO 34.5 5.8 34.5 83.1% SOx 0.0 0.0 0.0 0.0% TSP 0.2 0.2 0.2 0.0% PM10 0.2 0.2 0.2 0.0% PM2.5 0.2 0.2 0.2 0.0% Total HAPs* 0.0 0.0 0.3 0.0% *Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de minimus thresholds. PTE includes all HAPs calculated, even those below de minimus. Point Summary of Hazardous Air Pollutants (Ib/yr) HAP Name Uncontrolled Requested Controlled Requested PTE Proposed Efficiency Control Formaldehyde 380 380 380 0.0% Methanol * 57 0.0% Acetaldehyde * * 52 0.0% Acrolein * * 49 0.0% Benzene * * 29 0.0% 1,3 -Butadiene * * 12 0.0% Toluene * * 10 0.0% *Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED UNCONTROLLED is greater than de minimus Permitting Requirements Ambient Air Impacts Source details is of not required analysis) to model based on Division Guidelines/No NAAQS violations expected (see modeling Public Comment Public Comment Required/Public Comment not required MACT ZZZZ Missing or invalid entry information less than or equal to 500 HP located at a(n) Area Source Reg Standards 7 XVII.E (g/hp-hr) NOx: 1.0 CO: 2.0 VOC: 0.7 Reg requirements) 7 XVI.B (Ozone applies? NAA No MACT ZZZZ (area source) Is this source engine requirements? subject to MACT ZZZZ area No NSPS JJJJ Is this engine subject to NSPS JJJJ? TBD Note: been JJJJ adopted requriements into Reg are not 6. currently included as permit conditions because the reg has not Comments/Notes Previous permit coverage under GP02 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Timothy Sharp Package #: 390396 Received Date: 11/16/2018 Review Start Date: 9/20/2019 Section 01 - Facility Information Company Name: HighPoint Operating corporation County AIRS ID: 123 Quadrant Section Township Range SWNW 26 SN 62W Plant AIRS ID: 90F8 Facility Name: Physical Address/Location: County: Type of Facility: What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Anschutz State 5-62-26_25 SWNW SWNW quadrant of Section 26, Township SN, Range 62WW Weld County Exploration & Production Well Pad If yes, for what pollutant? Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Yes Particulate Matter (PM) Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks C Natural Gas RICE 4 Unit 17 Ye 19WE0837 Permit Initial Issuance previously GP02 003 Condensate Tank rndensate Tank Batter Ye 19WE0838 Permit initial issuance previously GP08 004 Produced Water Tank Water Storage Tanks 'yes 19WE0839 Permit Initial Issuance Previously G P08 C Separator Venting :kup flare open gas f Yes 15WE1435 Permit Modification Liquid Loading Tank Trucks 15WE1443 Permit Modification Natural Gas RICE_ C-16144/1 19WF0840 Permit Initial Issuance Previously GPC Section 03 - Description of Project Facility permit updates for new wells added Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) 5O2 ri Yes NOx CO VOC PM2.5 PM10 TSP HAPs J 1 J J Colorado Air Permitting Project Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) IA P1 No id NOx CO VOC PM2.5 PM10 TSP HAPs Condensate Storage Tank(s) Emissions Inventory 003 Condensate Tank 'Facility AIRs ID: 12, County 9D18 Plant 003 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: 10x400bbl Condensate Storage Tank Emission Control Device ECD Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = 652,020 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 652,020 Barrels (bbl) per year Requested Permit Limit Throughput = 782,424 Barrels (bbl) per year Requested Monthly Throughput = 66452 Barrels (bbl) per month 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 = 938,909 Barrels (bbl) per year 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? 22,348 MMBTU per year 26,818 MMBTU per year 32,181 MMBTU per year Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 1.43 7.15E-02 Site Specific ES, (€ncludes flash) Benzene 0.004 2.00E-04 Toluene 0.002 1.00E-04 Ethylbenzene 0.000 1.00E -0S Xylene 0.001 5.00E-05 n -Hexane 0.035 1.75E-03 224 TMP 0.000 5.00E-06 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 0.0000 AP -42 Chapter 13.5 Industrial Flares (NO)c) AP -42 Chapter 13.5 Industrial Flares (CO) PM2.5 0.0000 NOx 0.0680 0.0023 CO 0.3100 0.0106 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 PM10 PM2.5 NOx 671.3 466.2 23.3 559.4 28.0 4151 0.0 0.0 0.0 0.0 0.0 0 0.0 0.0 0.0 0.0 0.0 0 1.1 0.8 0.8 0.9 0.9 135 CO 5.0 3.5 3.5 4.2 4.2 70b Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene 3756 2603 130 3130 156 Toluene 1878 1304 65 1565 78 Ethylbenzene 188 130 7 156 8 Xylene 939 652 33 782 39 n -Hexane 32862 22821 1141 27385 1369 224 IMP 94 65 3 78 4 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-1 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) 3of8 K:\PA\2019\19WE0838 19WE0839.CP1 Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? No. If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. 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 control device efficiency greater than 95% for a flare or combustion device? No 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 Al 003 Process # SCC Code 01 4-04-003-11 Fixed Root Tank, Condensate, wolrking+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.06 0 lb/1,000 gallons condensate throughput VOC 34.0 95 lb/1,000 gallons condensate throughput CO 0.25 0 lb/1,000 gallons condensate throughput Benzene 0.10 95 lb/1,000 gallons condensate throughput Toluene 0.05 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.02 95 lb/1,000 gallons condensate throughput n -Hexane 0.83 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 Ib/1,000 gallons condensate throughput 4 of 8 K:\PA\2019\19WE0838 19WE0839.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements _ 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 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 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 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? Source requires a permit 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 No Yes Yes Yes Section XII C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII C.2 - 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? Yes Yes No Yes Storage Tank is not subject to Regulation 7, Section XII.G Section XII.G2 - Emissions Control Requirements Section XII C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII C.2 - 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 natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? No Yes Yes Yes Storage tank is subject to Regulation 7, Section XVII, B. C.1 & C.3 Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1 - Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? No Storage tank is subject to Regulation 7, Section XVII.C.2 Section XV11.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 (m1) (`472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m' (-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"; in 60.111b? 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 psi] and without emissions to the atmosphere (60.11ob(d)(2))?; or b. The design capacity is greater than or equal to 151 m3 ('950 BBL] and stores a liquid with a maximum true vapor pressure' less than 33 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m3 (^950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11ob(b))? No Source Req Go to next Source Req Continue -' Continue-' Source is st Continue-' Storage Tar Source is sit Continue -' Go to then Go to the n Source is sit Source is si. Storage Tar Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) 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"r per 603430? 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 -I? Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §605425 Table 3 460.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §603395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements (Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, 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: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel'` in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subiect to MACT 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 No RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is In the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as "recommend," "may," "should." and "can." is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Continue -' Storage Tar Continue - Storage Tar Produced Water Storage Tank(s) Emissions Inventory 004 Produced Water Tank I acility AIRs ID: County 9DF8 004 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 4x400bb1 Produced Water Storage Tank ECD 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = 1,245,S29 Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = Requested Permit Limit Throughput = 1,494,635 Barrels (bbl) per year Requested Monthly Throughput = 126942 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 1,793,562 Barrels (bbl) per year 701 3.7 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? 3,231 MMBTU per year 3,877 MMBTU per year 4,652 MMBTU per year Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) Emission Factor Source (Produced Water Throughput) (Produced Water Throughput) VOC 3.83E-02 1.92E-03 Benzene 9.OOE•04 4.50E-05 Toluene 5.00E-04 2.50E-05 Ethylbenzene 1.00E-04 5.00E-06 Xylene 2.00E-04 1.00E-05 n -Hexane 9.00E-04 4.50E-05 224 TMP 1.00E-04 5.00E-06 Control Device Emission Factor Source Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/bbl) (waste heat combusted) (Produced Water Throughput) PM10 0.0000 AP -42 Chapter 13.5 industrial Flares iiit..;;\; AP -42 Chapter 13.5 Ifidustria' PM2.5 0.0000 NOx 0.0680 0.0002 CO 0.3100 0.0008 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 34.3 23.9 1.2 28.6 1.4 243 PM10 0.0 0.0 0.0 0.0 0.0 0 PM2.5 0.0 0.0 0.0 0.0 0.0 0 NOx 0.2 0.1 0.1 0.1 0.1 22 CO 0.7 0.5 _ 0.5 0.6 0.6 102 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 1614 1121 56 1345 67 Toluene 897 623 31 747 37 Ethylbenzene 179 125 6 149 7 Xylene 359 249 12 299 15 n -Hexane 1614 1121 56 1345 67 224 TM 179 125 6 149 7 Section 06 - Regulatory Summary Analysis 1,245,529 Regulation 3, Parts A, B Not enough information 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 8 K:\PA\2019\19 W E0838 19WE0839.CP1 1 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? Yes 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 an "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 Yes Section 08 - Technical Analysis Notes l.: t '.':t':::::::'::111 ::11 .n.: z:: L: Y.... ..-.::::'11.::1::)1.:.1 M r'1 3� ��: •GNPr M x .t �.c_-s a, -fi'& : Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses 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 0.00 0 Ib/1,000 gallons liquid throughput VOC 0.9 95 lb/1,000 gallons liquid throughput CO 0.02 0 Ib/1,000 gallons liquid throughput Benzene 0.02 95 lb/1,000 gallons liquid throughput Toluene 0.01 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 0.02 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 7 of 8 K:\PA\2019\19WE0838 19WE0839.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Ncn-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 have indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the 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 11.0.2)? Not enough informati on 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 facility, natural gas compressor station3 or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions` of this storage tank equal to or greater than 6 tons per year VOC? 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 - Record keeping 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 XVlI.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 emissions2 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) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 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 determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is not a rule or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," "may, " "should." and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required" are intended to describe controPing requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Continue -' Continue -' Go to the n Source is st Source is si Continue -' Storage Tar STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1439 Issuance 3 DATE ISSUED: DRAFT ISSUED TO: HighPoint Operating Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Anschutz State 5-62-26_25 SWNW, located in the SWNW of Section 26, Township 5 North, Range 62 West, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Flare 005 Backup gas flare for when the produced gas is not able to be routed to the gathering system because it is down. Flare has a minimum control efficiency of 95%. The flare is not enclosed. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NOX VOC CO Backup Gas Flare 005 2.3 28.0 10.1 Point See "Notes to Permit Holder #4" for information on emission factors and methods used to calculate limits. AIRS ID: 123/9DF8 Page 1 of 7 Wellhead Version 2012-1 Colorado Department of Public Health and Environment Air Pollution Control Division Facility -wide emissions of each individual hazardous air pollutant shall be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 3. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Backup Gas Flare 005 Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 4. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the throughput shall be maintained by the applicant and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Backup Gas Flare 005 Natural gas flaring (process and pilot gas combined) 45.0 MMSCF The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 5. The owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 6. The permit number and AIRS ID number shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) AIRS ID: 123/9DF8 Page 2 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division 7. These sources are subject to the odor requirements of Regulation No. 2. (State only enforceable) 8. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 9. The open flare covered by this permit has been approved as an alternative emissions control device under Regulation Number 7, Section XVII.B.2.e. The open flare must have no visible emissions during normal operations and be designed so that an observer can, by means of visual observation from the outside of the open flare, or by other convenient means approved by the Division, determine whether it is operating properly. This open flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. OPERATING & MAINTENANCE REQUIREMENTS 10. Upon startup of these points, the applicant shall follow the operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 11. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 12. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. Annually 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 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. AIRS ID: 123/9DF8 Page 3 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. 13. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 14. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 15. 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 No. 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 16. This permit is issued in reliance upon the accuracy and completeness of information supplied by the applicant 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 applicant or applicant's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 17. 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. 18. 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 applicant, or the Division revokes a permit, the applicant AIRS ID: 123/9DF8 Page 4 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division or owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 19. 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. 20. 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: Timothy Sharp Permit Engineer Permit Histo Issuance Date Description Issuance 1 June 7, 2016 Issued to Bill Barrett Corporation. Newly permitted backup flare at a synthetic minor facility. Issuance 2 January 25, 2018 Issued to Bill Barrett Corporation Modification to reflect replacement of open flare with Make: Steffes model: DHPHC. Issuance 3 This Issuance Issued to HighPoint Operating Corporation. APEN Update AIRS ID: 123/9DF8 Page 5 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division Notes to Permit Holder: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the permittee 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 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 permittee shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aacc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (Ib/yr) 005 Benzene 71432 2966 Yes 148 Toluene 108883 3150 Yes 157 Ethylbenzene 100414 628 Yes 31 Xylenes 1130207 1952 Yes 98 n -Hexane 110543 21149 Yes 1057 5) The emission levels contained in this permit are based on the following emission factors: Point 005: CAS # Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled Emission Factors Controlled Source NOx -_ 0.068 lb/MMBtu 0.068 lb/MMBtu AP -42 CO -- 0.31 lb/MMBtu 0.31 lb/MMBtu AP -42 VOC 37.1 24884 lb/mmscf 1244.2 lb/mmscf Engineering Calculation 71432 Benzene 0.0983 65.9 lb/mmscf 3.295 lb/mmscf Engineering Calculation 108883 Toluene 0.1044 70.0 lb/mmscf 3.5 lb/mmscf Engineering Calculation 100414 Ethylbenzene 0.0208 13.9 lb/mmscf 0.695 lb/mmscf Engineering Calculation AIRS ID: 123/9DF8 Page 6 of 7 Colorado Department of Public Health and Environment Air Pollution Control Division CAS # Pollutant Weight Fraction of Gas (%) Emission Factors Uncontrolled Emission Factors Controlled Source 1330207 Xylenes 0.0647 43.4 lb/mmscf 2.17 lb/mmscf Engineering Calculation 110543 n -hexane 0.7010 470.0 lb/mmscf 23.5 lb/mmscf Engineering Calculation Note: The controlled VOC and HAP emissions factors for point 005 are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A — Subpart KKKK NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 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 AIRS ID: 123/9DF8 Page 7 of 7 a COLORADO Air Pollution Control Division Department of Pubic Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: CONSTRUCTION PERMIT 15WE1443 Issuance: 2 Date issued: Issued to: High Point Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: Description: Anschutz State 5-62-26_25 SWNW 123/9DF8 SWNW SEC 26 T5N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment ' Description Emissions Control Description Condensate Loadout 007 Truck loadout of condensate by submerged fill Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Condensate Loadout 007 -- --- 2.3 --- Point Page 1 of 8 a COLORADO Mr Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits for both criteria and hazardous air pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 4. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point, Control Device Pollutants Controlled Condensate Loadout 007 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit Condensate Loadout 007 Condensate Loaded 782,424 barrels The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and Page 2 of 8 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado keep a compliance record on site or at a local field office with site responsibility, for Division review. 6. Condensate loading to truck tanks must be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 7. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must 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.) 8 This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 9. 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 must be conducted by submerged file and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 10. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable." 11. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but knot limited to (Reference: Regulation Number 3, Part B, III.E): The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are, maintained to prevent dripping, leaking, or other liquid or, vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must 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. Page 3 of 8 COLORADO Air Pollution Control Division Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 12. For this controlled loading operation, the owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING Et MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III G 7 ) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. All previous versions of this permit are cancelled upon issuance of this permit. 17. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health £r Environment Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 5 of 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 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. V'otation 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: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 June 7, 2016 Issued to Bill Barrett Corporation. Newly permitted truck loadout at a synthetic minor facility. Issuance 2 This Issuance Issued to HighPoint Operating Corporation. Page 6 of 8 a COLORADO Air Pollution Control Division Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 007 Benzene 71432 321 16 n -Hexane 110543 2817 141 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.119 5.95E-03 SSEF Benzene 71432 4.10E-4 2.05E-05 PS Memo 14-02 n -Hexane 110543 3.60E-3 1.80E-04 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 2.82 psia M (vapor molecular weight) = 69 lb/lb-mol Page 7 of 8 a COLORADO Air Pollution Control Division Department of Public Wealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado T (temperature of liquid loaded) = 512 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Sou rce Requirements: Not Applicable 8) Full text of therTitle 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: / /www. ecfr. gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 STATE OF COLOFADO C< O C HE AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 PERMIT NO: 19WE0837 CONSTRUCTION PERMIT Issuance 1 DATE ISSUED: ISSUED TO: HighPoint Operating Corporation THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas facility, known as the Anschutz State 5-62-26_25 SWNW, located in SWNW SEC 26 T5N R62W, in Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description Unit 17 002 One (1) Doosan, Model D111TIC, Serial Number EEIOH404252, natural gas -fired, turbo -charged, 4SRB reciprocating internal combustion engine, site rated at 302 horsepower. This engine shall be equipped with a non- selective catalytic reduction (NSCR) system and air -fuel ratio control. This emission unit is used for electricity generation. This engine may be replaced with another engine in accordance with the temporary engine replacement provision or with another Doosan D111TIC engine in accordance with the permanent replacement provision of the Alternate Operating Scenario (AOS), included in this permit as Attachment A. THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND CONTROL ACT C.R.S. (25-7-101 et seq), TO THOSE GENERAL TERMS AND CONDITIONS INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS: REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manaqe-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section III.G.1 and can result in the revocation of the permit. AIRS ID: 123/9DF8/002 Page 1 of 15 NGEngine Version 2014-1 2. Within one issuance o l i =rm f c• • demonstr- • o the • 'is • . is he la e condi er or f Public Health and Environment Air Pollution Control Division r of commencement of operation or ns contained in this permit shall be rator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. (Reference: Regulation No. 3, Part B, III.G.2). 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) 4. The following information shall be provided to the Division within fifteen (15) days of the latter of commencement of operation or issuance of this permit. • manufacture date • construction date • order date • date of relocation into Colorado • manufacturer • model number • serial number This information shall be included with the Notice of Startup submitted for the equipment. (Reference: Regulation No. 3, Part B, III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type NO, VOC CO Unit 17 002 3.0 2.1 5.9 Point 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 be less than 8.0 tpy. Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month AIRS ID: 123/9DF8/002 Page 2 of 15 ora f Public Health and Environment Air Pollution Control Division a new twel mo �' t I all •- c ��ula K �• ased p n the previous twelve months' data. The permit <<+I• ha Tca la em each nth and keep a compliance record on site or - - ' •cal fi nsibi , or Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. 7. The emission points in the table below shall be operated and maintained with the control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit (Reference: Regulation No.3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Unit 17 002 Non -selective Catalytic Reduction and air/fuel ratio controller NOx and CO PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Process Parameter Annual Unit 17 002 Consumption of natural gas as a fuel 12.8 MMscf/yr Fuel consumption shall be measured by one of the following methods: individual engine fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of operation; or manufacturer -provided fuel consumption rate. The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.) (State only enforceable) AIRS ID: 123/9DF8/002 Page 3 of 15 orads let n f Public Health and Environment Air Pollution Control Division 10. Visible emi- ions al, o -xc-. d -nty ;e ent (-'1%) opacity during normal operation of the sour fd: -o-� � n• , eri s •° sta recess dification, or adjustment of control equipmen " ' • e e • n ` :'1 n • - - - • 30°° • • city for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions. (Reference: Regulation No. 1, Section I I.A.1. & 4.) 11. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 12. This equipment is subject to the control requirements for natural gas -fired reciprocating internal combustion engines under Regulation No. 7, Section XVII.E (State only enforceable). The owner or operator of any natural gas -fired reciprocating internal combustion engine that is either constructed or relocated to the state of Colorado from another state after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Maximum' Engine HP Construction or Relocation Date Emission Standard in g/hp-hr NOx CO VOC <100HP Any N/A N/A N/A ≥100HP and <500HP January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 ≥500HP July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 ' Maximum engine horsepower is the nameplate rating of the engine and does not account for deration. OPERATING & MAINTENANCE REQUIREMENTS 13. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Periodic Testing Requirements 14. This engine is subject to the periodic testing requirements as specified in the operating and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan are subject to Division approval. Replacements of this unit completed as Alternative Operating Scenarios may be subject to additional testing requirements as specified in Attachment A. AIRS ID: 123/9DF8/002 Page 4 of 15 ADDITIONAL R loradf Public Health and Environment Air Pollution Control Division 15. A revised N) filed: (Reference: Regulation No. 3, Part A, I I.C) a. Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. f. Within 14 calendar days of commencing operation of a permanent replacement engine under the alternative operating scenario outlined in this permit as Attachment A. The APEN shall include the specific manufacturer, model and serial number and horsepower of the permanent replacement engine, the appropriate APEN filing- fee and a cover letter explaining that the owner or operator is exercising an alternative -operating scenario and is installing a permanent replacement engine. 16. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation No. 3 Part D). GENERAL TERMS AND CONDITIONS 17. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. AIRS ID: 123/9DF8/002 Page 5 of 15 orad e n f Public Health and Environment Air Pollution Control Division 18. If this per ation has been granted, then the remainder • th `on•e io n apps a• Othe' se, the issuance of this construction permit do • pro • fi - th • • '' is a 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 No. 3, Part B, Section I II.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 19. 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. 20. 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. 21. 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. 22. 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. 23. 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: Timothy sharp Permit Engineer AIRS ID: 123/9DF8/002 Page 6 of 15 Permit Hi f Public Health and Environment Air Pollution Control Division Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation. AIRS ID: 123/9DF8/002 Page 7 of 15 brad Notes to Permit Hold f Public Health and Environment Air Pollution Control Division 1) The permit hol• - essi - • e for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdohe/aacc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # BIN Uncontrolled Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 002 Formaldehyde 50000 A 380 Yes 380 Methanol 67561 C 57 No 57 Acetaldehyde 75070 A 52 No 52 Acrolein 107028 A 49 No 49 Benzene 71432 A 29 No 29 1,3 -Butadiene 106990 A 12 No 12 Toluene 108883 C 10 No 10 5) The emission levels contained in this permit are based on the following emission factors: Point 002: CAS Pollutant Emission Uncontrolled lb/MMBtu Factors - g/bhp-hr Emission Controlled Ib/MMBtu Factors — g/bhp-hr NOx 2.2100 7.0 0.3094 1.0 CO 3.7200 11.82 0.6287 2.00 VOC 0.2204 0.70 0.2204 0.70 50000 Formaldehyde 0.0205 0.07 0.0205 0.07 67561 Methanol 0.0031 0.01 0.0031 0.01 75070 Acetaldehyde 0.0028 0.01 0.0028 0.01 107028 Acrolein 0.0026 0.01 0.0026 0.01 71432 Benzene 0.0016 0.01 0.0016 0.01 AIRS ID: 123/9DF8/002 Page 8 of 15 lorad f Public Health and Environment Air Pollution Control Division CAS ollu - E ssi. nc /M - Factor trolled g/r Emission Controlled lb/MMBtu Factors — g/bhp-hr 106990 1,3 -Butadiene 0.0007 0.00 0.0007 0.00 108883 Toluene 0.0006 0.00 0.0006 0.00 Emission factors are based on a Brake -Specific Fuel Consumption Factor of 7003 Btu/hp-hr, a site - rated horsepower value of 302, and a fuel heat value of 1447 Btu/scf. Emission Factor Sources: CAS Pollutant Uncontrolled EFSource Controlled EF Source NOx JJJJ CO JJJJ VOC JJJJ 50000 Formaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 67561 Methanol AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 75070 Acetaldehyde AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 107028 Acrolein AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 71432 Benzene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 106990 1,3 -Butadiene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 108883 Toluene AP -42; Table 3.2-3 (7/2000); Natural Gas No Control 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal Register posting — effective March 18, 2008). This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available on the EPA website at: http://www.epa.povittn/atw/area/fr18ia08.pdf 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO, HAPs NANSR Synthetic Minor Source of: VOC, NOx MACT ZZZZ Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ AIRS ID: 123/9DF8/002 Page 9 of 15 f Public Health and Environment Air Pollution Control Division Part 60: Stan `. rds P oan . - for ew ationa ources NSPS 6r.- nd ub•- °� — ubpa K NSPS Part 60, Appendixes Appendix A — Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A — Subpart Z MACT 63.600-63.1199 Subpart AA — Subpart DDD MACT 63.1200-63.1439 Subpart EEE — Subpart PPP MACT 63.1440-63.6175 Subpart QQQ — Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXX( 10) A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification AIRS ID: 123/9DF8/002 Page 10 of 15 f Public Health and Environment Air Pollution Control Division ENARIOS RECIPROCATING INTERNAL COMBUSTION ENGINES October 12, 2012 2. Alternative Operating Scenarios The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of Regulation No. 3., Part A, Section IV.A, Operational Flexibility -Alternative Operating Scenarios, Regulation No. 3, Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine replacement without applying for a revision to this permit or obtaining a new Construction Permit. 2.1 Engine Replacement The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month period. "Permanent" is defined as in the same service for more than 90 operating days in any 12 month period. The 90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that day shall count as a single day towards the 90 day total. The compliance demonstrations and any periodic monitoring required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit. All replacement engines are subject to all federally applicable and state -only requirements set forth in this permit (including monitoring and record keeping). The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within 30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with NSPS or MACT requirements. Results of all tests shall be kept on site for five (5) years and made available to the Division upon request. The owner or operator shall maintain a log on -site and contemporaneously record the start and stop date of any engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all Applicability Reports required under section 2.1.2 and make them available to the Division upon request. 2.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary replacement engine complies with all permit limitations and other requirements applicable to the existing engine. Measurement of emissions from the temporary replacement engine shall be made as set forth in section 2.2. AIRS ID: 123/9DF8/002 Page 11 of 15 ora f Public Health and Environment Air Pollution Control Division 2.1.2 The owner or •s erato _ p. an� tl -pla t e exi• ;ng engine with another engine with the same manufacturer, o• - a hi .ep .' er gin ! withou modifying this permit so long as the permanent replace gin PI `'' al itati. - d other requirements applicable to the existing engine as well as any new applicable requirements for the replacement engine. Measurement of emissions from the permanent replacement engine and compliance with the applicable emission limitations shall be made as set forth in section 2.2. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement engine within 14 calendar days of commencing operation of the replacement engine. The APEN shall be accompanied by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative operating scenario and is installing a permanent replacement engine, and a copy of the relevant Applicability Reports for the replacement engine. Example Applicability Reports can be found at www.colorado.00v/cdphe/air/AOS. This submittal shall be accompanied by a certification from the Responsible Official indicating that "based on the information and belief formed after reasonable inquiry, the statements and information included in the submittal are true, accurate and complete". This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine that is not subject to emission limits. The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information submitted to the Division in regard to any permanent engine replacement. 2.2 Portable Analyzer Testing Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing requirements. Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for another three months). The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this Condition, if approved in advance by the Division. The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation of the replacement engine. All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at: www.colorado.gov/cdnhe/nortable-analyzer-monitorinci-Drotocol Results of the portable analyzer tests shall be used to monitor the compliance status of this unit. For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year (whichever applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be multiplied by the maximum number of hours in the month or year (8760), whichever applies. For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement AIRS ID: 123/9DF8/002 Page 12 of 15 ora engine will be subjec the above-mentione f Public Health and Environment Air Pollution Control Division cr vert to the appropriate units as described in ocol doc ent. If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and CO emission limitations for the relevant time period. Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline. 2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2 All permanent replacement engines that are located in an area that is classified as attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT) for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which the area is in attainment/maintenance or nonattainment, except as follows: In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr. For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal combustion engines: VOC: The emission limitations in NSPS JJJJ CO: The emission limitations in NSPS JJJJ NOX: The emission limitations in NSPS JJJJ SO2: Use of natural gas as fuel PM10: Use of natural gas as fuel As defined in 40 CFR Part 60 Subparts GG (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains 20.0 grains or less of total sulfur per 100 standard cubic feet. 2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State - Only conditions). Control Requirements: Section XVI Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the applicable control requirements specified in Regulation No. 7, section XVI, as specified below: Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non -selective catalyst and air fuel controller to reduce emission. Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to reduce emissions. The above emission control equipment shall be appropriately sized for the engine and shall be operated and maintained according to manufacturer specifications. The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. AIRS ID: 123/9DF8/002 Page 13 of 15 ora Emission Standards: f Public Health and Environment Air Pollution Control Division Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the date listed in the table below shall operate and maintain each engine according to the manufacturer's written instructions or procedures to the extent practicable and consistent with technological limitations and good engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards required in the table below: Max Engine HP Construction or Relocation Date Emission Standards in G/hp-hr NOx CO VOC 100<Hp<500 January 1, 2008 January 1, 2011 2.0 1.0 4.0 2.0 1.0 0.7 500≤Hp July 1, 2007 July 1, 2010 2.0 1.0 4.0 2.0 1.0 0.7 The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2. 2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater than 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements of 40 CFR Part 60, Subpart JJJJ. An analysis of applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the NSPS is in addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of Regulation No. 6 (i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture date for purposes of determining the applicability of NSPS JJJJ requirements). However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § l.B (which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ. 2.3.4 Reciprocating internal combustion engine (RICE) MACT: 40 CFR Part 63, Subpart ZZZZ A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the MACT can serve as the testing required by this AOS under Condition 2.2, if approved in advance by the Division, provided that such test is conducted within the time frame specified in Condition 2.2. AIRS ID: 123/9DF8/002 Page 14 of 15 Public Health and Environment Air Pollution Control Division 2.4 Additional Sourc The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation. AIRS ID: 123/9DF8/002 Page 15 of 15 COLORADO Air Pollution Control Division Department of Pubic Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0838 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 HighPoint Operating Corporation Anschutz State 5-62-26_25 SWNW 123/9DF8 SWNW SEC 26 T5N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tank Battery 003 Ten (10) 400 barrel fixed roof storage vessels used to store condensate Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (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 must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 10 a COLORADO Mr Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO Condensate Tank Battery 003 -- --- 28.1 4.2 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 10 a COLORADO Mr Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Condensate Tank Battery 003 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Condensate Tank Battery 003 Condensate throughput 782424 barrels , The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • 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 Page 3 of 10 a COLORADO Mr Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design, destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING a MAINTENANCE REQUIREMENTS 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O8M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements Page 4 of 10 a 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 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the Last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. Page 5 of 10 a 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 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Page 6 of 10 a 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 History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation Page 7 of 10 a COLORADO Air Pollution Control Division Department of Pubtc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated .based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 2365 119 Toluene 108883 ` 1130 57 Ethylbenzene 100414 119 6 Xylenes 1330207 332 18 n -Hexane 110543 22942 1148 2,2,4- Trimethylpentane 540841 8 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source CO .31 lb/MMbtu AP -42 VOC 1.43 7.15E-02 SSEF 71432 Benzene .004 2.00E-04 SSEF 108883 Toluene .002 1.00E-04 SSEF Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 1330207 Xylene .001 5.00E-05 SSEF 110543 n -Hexane .035 1.75E-03 SSEF Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC'. NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM Page 9 of 10 a COLORADO Air Pollution Control Division Departnmr _ t of Public Wealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: I9WE08 3 9 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description: Issuance: 1 HighPoint Operating Corporation Anschutz State 5-62-26_25 SWNW 123/9DF8 SWNW SEC 26 T5N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment lD AIRS ! Equipment Description Point Description Emissions Control Water Storage Tanks 004 Four (4) 400 barrel fixed roof storage vessels used to store produced water Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 It COLORADO Air Pollution Control Division Department of Public Health b Envinn anent Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO Water Storage Tanks 004 --- --- 0.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Water Storage Tanks 004 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Water Storage Tanks 004 Produced Water throughput 1,494,635 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means Page 3 of 8 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OItM plan are subject to Division approval prior to implementation. (Regulation Number 3 Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 4 of 8 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type, of control equipment; or Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation No. 3, Part D must apply at such stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. time that any Page 5 of 8 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation Page 6 of 8 a COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:'https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 004 Benzene 71432 302 16 Toluene 108883 165 10 Ethylbenzene 100414 16 2 Xylenes 1330207 45 4 n -Hexane 110543 291 16 2,2,4- Trimethylpentane 540841 25 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 3.83E-02 1.92E-03 SSEF 71432 Benzene 9.00E-04 4.50E-05 SSEF 110543 n -Hexane 9.00E-04 4.50E-05 SSEF Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 7 of 8 COLORADO Air Pollution Control Division Department of Pubic Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: httta://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 a„ COLORADO Mr Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0839 Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: Description Issuance: 1 HighPoint Operating Corporation Anschutz State 5-62-26_25 SWNW 123/9DF8 SWNW SEC 26 T5N R62W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Water Storage Tanks 004 Four (4) 400 barrel fixed roof storage vessels used to store produced water Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, 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 must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 f� 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 compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Water Storage Tanks 004 --- --- 0.4 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. Page 2 of 8 a COLORADO Air Pollution Control Division Departrner _ t of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Water Storage Tanks 004 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Water Storage Tanks 004 Produced Water throughput 1,494,635 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means Page 3 of 8 a COLORADO Mr Pollution Control Division Department of Public Health Fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this, permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 4 of 8 a COLORADO Air Pollution Control Division Departr,mr _ t of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or, operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. Page 5 of 8 a 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 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation Page 6 of 8 4%0 COLORADO Air Pollution Control Division Department of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions , (lb/yr) Controlled Emissions (lb/yr) 004 Benzene 71432 302 16 Toluene 108883 165 10 Ethylbenzene 100414 16 2 Xylenes 1330207 45 4 n -Hexane 110543 291 16 2,2,4 Trimethylpentane 540841 25 2 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 3.83E-02 1.92E-03 SSEF 71432 Benzene 9.00E-04 4.50E-05 SSEF 110543 n -Hexane 9.00E-04 4.50E-05 SSEF Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 7 of 8 It COLORADO Air Pollution Control Division Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH Area Source Requirements: Not Applicable 9) Full text of the Title 40 Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS ' 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Spark Ignition Engine APEN Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit RECEIVED NOV 1 8 2018 APCD SticionarY Ourena 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 APE illed out incorrectly or is missing information and requires re -submittal. This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combusti ig'' ' Ejj your engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall in category, there may be a more specific APEN for your source (e.g. compression ignition engine, "'- ratios asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if th specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollfon 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: 161 1NE 0 1 AIRS ID Number: 123 / 9DF8 / 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: Site Name: Site Location: HighPoint Operating Corporation Anschutz State 5-62-26_25 SWNW Site Location SWNW Sec 26, T5N, R62W County: Weld Mailing Address: (Include Zip Code) 1099 18th St., Suite 2300 Portable Source Home Base: Denver, CO 80202 .NAICS or SIC Code: Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 390390 1i AY COLORADO tdPublic Ree4mfr 6n,e,nmem Permit Number: AIRS ID Number: 123 /9DF8/ 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) ❑✓ STATIONARY source ❑ PORTABLE source ❑✓ Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,875 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment O Change company name4 O Add point to existing permit O Change permit limit ❑ Transfer of ownerships O Other (describe below) -OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit-exempt/grandfathered source O Notification of Alternate Operating Scenario (AOS) permanent replacement6 Additional Info Et Notes: Previously a GP02 change to site specific construction permit. 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. S For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? If yes, provide the Company Equipment Identification No. Unit 17 Yes General description of equipment and purpose: Generator engine (TP 28798) used for electricity generation For existing sources, operation began on: 8/19/2015 For new or reconstructed sources, the projected start-up date is: Wilt this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.gov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 D Yes ❑ No Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 © COLORADO Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I Lit int Permit Number: AIRS ID Number: 123 /9DF8/ 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑✓ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑ Compression ❑ Pump Jack O Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? hours/year Engine Make: Doosan Engine Model: D111TIC Serial Number7: EEIOH404252 What is the maximum designed horsepower rating? 302 hp What is the maximum manufacturer's site -rating? hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,003 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke Combustion: ❑ Lean Burn ❑✓ Rich Burn Aspiration: O Natural ❑✓ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? O Yes ❑✓ No If yes, what type of AFRC is in use? ❑ 02 Sensor (mV) ❑NOx Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOx design? O Yes 0 No Engine Dates: What is the manufactured date of this engine? 11/26/2014 What date was this engine ordered? Unknown What is the date this engine was first located to Colorado? 2015 What is the date this engine was first placed in service/operation? Unknown What is the date this engine commenced construction? Unknown What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? O Yes ❑✓ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 I A`6 COLORADO Dqvseraera mP Heath@Enrinnww?I ✓Q Upward ❑ Horizontal Permit Number: AIRS ID Number: 123 /9DF8/ 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.373914, -104.299003 Operator Stack ID No, Discharge Height, Above Ground Level (feet) Temp. (° F) Flow Rate (ACFM) Velocity (ft>sec) 8 1,382 1,261 Indicate the direction of the Stack outlet: (check one) ❑ Downward Other (describe): Indicate the stack opening and size: (check one) ✓0 Circular ❑ Square/Rectangle Ei Other (describe): Interior stack diameter (inches): Interior stack diameter (inches): ❑ Upward with obstructing raincap Interior stack depth (inches): Section 6 - Fuel Data and Throughput Information Fuel Use Rate @ 100% Load (SCF/ hour) Actual Annual Fuel Use (MMSCF/year( Requested Annual Permit Limit' (MMSCF/year) 1,462 12.8 From what year is the actual annual amount? 2018 Indicate the type of fuel used9: Ej Pipeline Natural Gas 0 Field Natural Gas El Propane ❑ Landfill Gas ❑ Other (describe): (assumed fuel heating value of 1,020 8TU/scf) Heating value: 1,447 BTU/scf (assumed fuel heating value of 2,300 8TU/scf) Heating Value: BTU/scf Heating Value (give units): 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4j a__" COLORADO Department of public , tee k €nvhen_neni Permit Number: AIRS ID Number: 123 /9DF8/ 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? Q✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP (PM) PMto PM2.5 SOX NOx NSCR 86 VOC CO NSCR 83 Other: Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions1° Permit Requested Annual P Emission Limits) Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) TSP (PM) 9.50E-3 Ib/MMbtu AP -42 0.09 0.09 0.09 0.09 PM10 9.50E-3 Ib/MMbtu AP -42 0.09 0.09 0.09 0.09 PM2.5 9.50E-3 Ib/MMbtu AP -42 0.09 0.09 0.09 0.09 SOX 5.88E-4 Ib/MMbtu AP -42 0.01 0.01 0.01 0.01 NOx 2.21E+0 Ib/MMBtu AP -42 20.48 2.92 20.48 2.92 VOC 0.70 g/hp-hr JJJJ 2.05 2.05 2.05 2.05 CO 3.72E+0 Ib/MMBtu AP -42 34.47 5.84 34.47 5.84 Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 ❑ Yes ✓0 No lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions1° Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Formaldehyde 50000 2.05E-2 Ib/MMBtu AP -42 380 380 Acetaldehyde 75070 2.79E-3 Ib/MMbtu AP -42 52 52 Acrolein 107028 2.63E-3 Ib/MMbtu AP -42 49 49 Benzene 71432 1.58E-3 Ib/MMbtu AP -42 29 29 Other: 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5I COLORADO IN aewca!P,** lieges gnv1total I Permit Number: AIRS ID Number: 123 /9DF8/ 002 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. Signature of Legally Authorize Person (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance E Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $1,875, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD websitat: ; https://www.colorado.gov/cdphe/amd Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 6 I Ahlf COLORADO etivUle Spark Ignition Engine APEN Form APCD-201 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for spark ignition (e.g. gas -fired) reciprocating internal combustion engines (RICE). If your engine is a compression ignition engine (e.g. diesel -fired) or your emission unit does not fall into the RICE category, there may be a more specific APEN for your source (e.g. compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options do not meet your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: CETVED NOV 1 6 2018 APCD Stationary AIRS ID Number: 123 /On/ / ode [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz State 5-62-26_25 SWNW Site Location: SWNW Sec 26, T5N, R62W Mailing Address: (Include Zip Code) 1099 18th St., Suite 2300 Portable Source Home Base: Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 390389 1I AV COLORADO HealAaE .irermam Permit Number: AIRS ID Number: 1 23 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source (check one below) p STATIONARY source ❑ PORTABLE source ❑✓ Request coverage under a Construction Permit O Request coverage under General Permit GP023 (Natural Gas Only) If General Permit coverage is requested, the General Permit registration fee of $1,875 must be submitted along with the APEN filing fee. - OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name4 0 Add point to existing permit O Change permit limit 0 Transfer of ownerships ❑ Other (describe below) - OR - • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ APEN submittal for permit-exempt/grandfathered source o Notification of Alternate Operating Scenario (AOS) permanent replacement6 Additional Info ft Notes: Previously GP02 change to site specific construction permit. Reassign AIRS ID to 123-9DF8 to coincide with associated production facility. 3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary. 4 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 5 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. 6 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements. Section 3 - General Information Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc.)? If yes, provide the Company Equipment Identification No. C-16144/1 General description of equipment and purpose: used for natural gas compression Yes Waukesha L7044GSI Compressor Engine For existing sources, operation began on: 4/2/2018 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? (http://www.colorado.pov/cdphe/attainment) Normal Hours of Source Operation: 24 hours/day 7 ❑✓ Yes ❑ No Seasonal use percentage: Dec -Feb: 25 Mar -May: 25 days/week 52 weeks/year June -Aug: 25 Sept -Nov: 25 Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 2 I ':p' Matt, MIONTHFIRPI COLORADO Permit Number: AIRS ID Number: 123 / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Engine Information Engine Function: ❑ Primary and/or Peaking Power ❑ Emergency (max. 500 hrs/year) ❑✓ Compression ❑ Pump Jack ❑ Water Pump ❑ Other: What is the maximum number of hours this engine will be used for emergency back-up power? N/A hours/year Engine Make: Waukesha Engine Model: L7044 GSI Serial Number7: C-16144/1 What is the maximum designed horsepower rating? 1,680 hp What is the maximum manufacturer's site -rating? hp kW What is the engine Brake Specific Fuel Consumption at 100% Load? 7,881 BTU/hp-hr Engine Features: Cycle Type: ❑ 2 -Stroke 0 4 -Stroke Combustion: ❑ Lean Burn 0 Rich Burn Aspiration: ❑ Natural ✓❑ Turbocharged Is this engine equipped with an Air/Fuel ratio controller (AFRC)? 0 Yes O No If yes, what type of AFRC is in use? 0 02 Sensor (mV) ❑NOx Sensor (ppm) ❑ Other: Is this engine equipped with a Low-NOx design? ❑ Yes 0 No Engine Dates: What is the manufactured date of this engine? 02/2006 What date was this engine ordered? Unknown What is the date this engine was first located to Colorado? 2014 What is the date this engine was first placed in service/operation? Unknown What is the date this engine commenced construction? Unknown What is the date this engine was last reconstructed or modified? N/A Is this APEN reporting an AOS replacement engine? O Yes ✓❑ No If yes, provide the make, model, and serial number of the old engine below: Engine Make: Engine Model: Serial Number: 7 The serial number must be submitted if coverage under GP02 is requested. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 3 1 AV COLORADO Hee{M4 EngreMnrm 0✓ Upward ❑ Horizontal Permit Number: AIRS ID Number: 123 I / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.367408/ -104.301567 OperatorTemp. Stack ID No. Discharge Height Above Ground Level (feet) CF) Flow Rate (ACFM) Velocity (fUsec) C-16144/1 25 1,179 8,162 Indicate the direction of the Stack outlet: (check one) ❑ Downward Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): 0 Square/Rectangle Interior stack diameter (inches): ❑ Other (describe): 15 ❑ Upward with obstructing raincap Interior stack depth (inches): Section 6 - Fuel Data and Throughput information Fuel Use Rate @ 100% Load (SCF/ hour) Actual Annual Fuel Use (MMSCFI year) Requested Annual Permit Limit$ (MMSCFI year) 9,150 80.1 From what year is the actual annual amount? 2018 Indicate the type of fuel used9: Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf) 0 Field Natural Gas Heating value: 1,447 BTU/scf Propane (assumed fuel heating value of 2,300 BTU/scf) 0 Landfill Gas Heating Value: BTU/scf 0 Other (describe): Heating Value (give units): $ Requested values will become permit limitations. Requested limit(s) should consider future process growth. 9 If fuel heating value is different than the listed assumed value, provide this information in the "Other" field. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 4 I 407 COLORADO .4 -pan -aunt of P.62Ic n,Ecth E_nwimmmm Permit Number: AIRS ID Number: 123 I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a Natural Gas Fired Engines Calculator available to assist with emission calculations. Is any emission control equipment or practice used to reduce emissions? 0✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Primary Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) TSP. (PM) PM10 PM2.5 SOx NOx NSCR 92 vOC CO NSCR 82 Other: Use the following tables to report criteria and non -criteria pollutant emissions from source: (Use the data reported in Section 6 to calculate these emissions.) From what year is the following reported actual annual emissions data? 2O18 Criteria Pollutant Emissions Inventory • Pollutant Emission Factor Actual Annual Emissions10 Requested Annual Permit Emission Limit(s)8 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) TSP (PM) 9.50E-3 Ih/MMbtu AP -42 - 0.56 0.56 .0.56 0.56 PM10 9.50E-3 Ib/MM htu AP -42 0.56 0.56 0.56 0.56 PM2.5 9.50E-3 Ib/MMbtu AP -42 0.56 0.56 0.56 0.56 SOx 5.88E-4 Ib/MMbtu AP -42 0.04 0.04 0.04 0.04 NOx 13.30 g/hp-hr MFR. 215.77 16.23 215.77 16.23 VOC 0.70 g/hp-hr JJJJ 11.36 11.36 11.36 11.36 CO 11.20 g/hp-hr MFR 181.70 32.45 181.70 32.45 Does the emissions source have any uncontrolled actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 0✓ Yes ❑ No lbs/year? If yes, please use the following table to report the non -criteria pollutant (HAP) emissions from source: Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissionsl0 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (pounds/year) Controlled Emissions (pounds/year) Formaldehyde 50000 0.05 g/hp-hr MFR. 1,622 1,622 Acetaldehyde .75070 2.79E-3 Ib/MMbtu AP -42 324 324 Acrolein 107028 2.63E-3 'Ib/MMbtu AP -42 305 305 Benzene 71432 1.58E-3 Ib/MMbtu AP -42 183 183 Other: 67-56-1 3.06E-3 Ib/MMBtu AP -42 355 355 8 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 5I COLORADO 4 l ,8 , , Permit Number: AIRS ID Number: 123 I [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP02, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP02. Signature of Legally Authorized F rson (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $1,875, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.Rov/edphe/apcd Form APCD-201 - Spark Ignition Engine APEN - Revision 7/2018 6 AyI` Heel B6nHmne em RECEIVED Condensate Storage Tank(s) APEN Nov 1 6 2018 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: 1g Vv8 0 S 3g AIRS ID Number: 123 ' 9DF8 ' 003 APCD Stationary [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz State 5-62-26_25 SWNW Site Location: SWNW Sec 26, T5N, R62W Mailing Address: (Include Zip Code) 1099 18th St., Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 390391 �TIICOLORADO 1 I V:l maw' Mi�+7 Permit Number: AIRS ID Number: 123 / 9DF8 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ❑✓ Request coverageunder traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR - ▪ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 ❑ Change permit limit 0 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 & Notes: Previously GP08 being re -permitted as site specific construction permit. Increased number of tanks and increase emission and throughput limit due to the addition of new wells. 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 Tank Battery 08/01/2015 For new or reconstructed sources, the projected start-up date is: 08/22/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week . 52 weeks/year ❑✓ Exploration & Production (E&P) site 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? O Yes • No Are Flash Emissions anticipated from these storage tanks? O Yes ■ No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? 0 Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: 0.00219 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 • O 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 O ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 W (COLORADO 2 I L�f7 Depuueanrcl Putnc He6i911fEJIF76QnInQ!!1 Permit Number: AIRS ID Number: 123 / 9DF8 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Condensate Throughput: Actual Annual Amount (bbl/year) 652,020 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 37.1 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof Requested Annual Permit Limits (bbl/year) 782,424 RVP of sales oil: 6.0 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) 10 4,000 08/2018 08/2015 Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only) API Number Name of Well Newly Reported Well - See attached form APCD 212 ■ - - ■ - - ■ _ _ ■ - - ■ 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 UM) 40.372841/-104.299505 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) 30 550 Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular ❑ Square/rectangle ❑ Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): 84 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 AV COLORADO Gga,Imrntol Yukilc 3 I thannsgammnimet Permit Number: AIRS ID Number: 123 / 9DF8 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: 1.88 MMBtu/hr Type: (3) ECD Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Cimarron/Big Hurt Waste Gas Heat Content: 2,742 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.0004 MMBtu/hr ❑ Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 13.7 psig Describe the separation process between the well and the storage tanks: High Pressure 3 -phase separator to heater treater to VRT to atmospheric tanks. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 ---�IGOLORA00 C.y�mmntot 16M1n 4 I RveVn46nvinnw¢et Permit Number: AIRS ID Number: 123 / 9DF8 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled is Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) Controlled Emissionse (Tons/year) Uncontrolled Emissions (Tens/year) Controlled Emissions (Tons/year) VOC 1.43 lb/bbl SSEF 467 23.4 561 28.1 NOx 6.80E-2 lb/MMBtu AP -42 0.77 0.92 CO 3.10E-1 lb/MMBtu AP -42 3.48 4.16 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 Emissions8 (Pounds/year) Benzene 71432 4.00E-3 lb/bbl SSEF 2,365 119 Toluene 108883 2.00E-3 lb/bbl SSEF 1,130 57 Ethylbenzene 100414 2.00E-4 lb/bbl SSEF 119 6 Xylene 1330207 1.00E-3 lb/bbl SSEF 332 18 n -Hexane 110543 3.50E-2 lb/bbl SSEF 22,942 1,148 2,2,4- Trimethylpentane 540841 1.00E-4 lb/bbl SSEF 8 2 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 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 AlCOLORADO 5 � N.grfrB,tCmee, Permit Number: AIRS ID Number: 123 / 9DF8 / 003 [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 GPM, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. ��-rS �►- l8' Signature of Legally Authorized11-Person (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: ✓D 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 websitelot: ,. https: //www.colora& .ciov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 A 'COLORADO Alf uy�ro�+rcat wttm 6 I HraWc%Enr7[anmw_rt Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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. ocevED N�V 1,019 Permit Number: AIRS ID ICIWEOS301 Number: 123 /9DF8/OO4 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Anschutz State 5-62-26_25 SWNW Site Location: SWNW Sec 26, T5N, R62W Mailing Address: (Include Zip Code) 1099 18th St., Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: p?CD 5ncY Soor ea Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 39039g COLORADO , Permit Number: AIRS ID Number: 123 / 9DF8 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Previously GP08 being re -permitted as site specific construction permit. Increased number of tanks and increase emission and throughput limit due to the addition of new wells. 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: Water Storage Tanks 08/01/2015 For new or reconstructed sources, the projected start-up date is: 08/22/2018 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ❑✓ Exploration & Production (E&P) site ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? IN Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions a 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 2 I art COLORADO brprementuffill4c ftvum&FnY7140IMM Permit Number: AIRS ID Number: 123 / 9DF8 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbl/year) 1,245,529 Requested Annual,Permit Limits (bbl/year) 1,494,635 From what year is the actual annual amount? Tank design: Fixed roof 2018 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) 4 1,800 08/2018 08/2O15 Wells Serviced by this Storage Tank or Tank Batter? (E&P Sites On y) API Number Name of Well . Newly Reported Well - - See attached form APCD 212 ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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 U'TM) 40.373914/-104.299003 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (V) Flow Rate (ACFM) Velocity (ft/sec) 30 550 Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Horizontal ❑ Downward ❑Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): 84 ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑Other (describe): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 3 COLORADO 1,4.,:r•,* tit PuHlc rves�nFE„mmthn1 Permit Number: AIRS ID Number: 123 / 9DF8 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor O Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: Make/Model: VRU Downtime or Bypassed (emissions vented): ❑✓ Combustion Device: Pollutants Controlled: VOC/HAPs Rating: 1,88 MMBtu/hr Type: (3) ECD Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Cimarron/Big Hurt Waste Gas Heat Content: 2,742 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.0004 MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 129 psig Describe the separation process between the well and the storage tanks: High pressure 3 -phase separator to atmospheric tanks. 4 I nay (COLORADO Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 R,°n" Permit Number: AIRS ID Number: 123 / 9DF8 / 004 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (%reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC ECD 95 NOx CO HAPs ECD 95 Other: From what year is the following reported actual annual emissions data? 201 8 Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions a (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 3.83E-2 lb/bbl SSEF 6.6 0.3 7.9 0.4 NOx 6.80E-2 Ib/bbl SSEF 0.1 0.1 CO 3.10E-1 Ib/bbl SSEF 0.2 0.2 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 Emissions8 (pounds/year) Benzene 71432 9.00E-4 lb/bbl SSEF 302 16 Toluene 108883 5.00E-4 Ib/bbl SSEF 165 10 Ethylbenzene 100414 1.00E-4 lb/bbl SSEF 16 2 Xylene 1330207 2.00E-4 lb/bbl SSEF 45 4 n -Hexane 110543 9.00E-4 Ib/bbl SSEF 291 16 2,2`4 Trimethylpentane 540841 1.00E-4 lb/bbl SSEF 25 2 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. a 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 5 COLORADO . i mx,',1lFtiU = rsnc��;+�€aeuan .es Permit Number: AIRS ID Number: 123 / 9DF8 / 004 [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. Signature of Legally Authorized Person (not a vendor or consultant) Date Marsha Sonderfan EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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 amyl COLORADO mx2.4€4enm.n RECErvED N"'$2019 Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 15WE1443 AIRS ID Number: 123 / 9DF8 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: HighPoint Operating Corporation Site Name: Anschutz State 5-62-26_25 SWNW Site Location: SWNW Sec 26, T5N, R62W Mailing Address: (Include Zip Code) 1099 18th St., Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 394 'COLORADO a:y,raes�.pt� Permit Number: 15WE1443 AIRS ID Number: 123 / 9DF8 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action O NEW permit OR newly -reported emission source O Request coverage under construction permit O 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 O Change company name3 p Change permit limit ❑ Transfer of ownership4 O Other (describe below) - OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: Increase permit limit due to the addition of new wells. 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: Hydrocarbon liquids are removed from the site via truck loadout. Truck loadout vapors are routed to the ECD knockout drum and directed to the ECDs for control Company equipment Identification No. (optional): For existing sources, operation began on: 08/15/2015 For new or reconstructed sources, the projected start-up date is: 08/01/2018 Will this equipment be operated in any NAAQS nonattainment area? Yes No IN ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No ■ p Is this source located at an oil and gas exploration and production site? Yes No O ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No 0 ■ Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ NI 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 21AY 'COLORADO B s maveW wtm Permit Number: 15WE1443 AIRS ID Number: 123 / 9DF8 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: 0 Condensate O . Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 782,424 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") 652,020 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 52 J °F True Vapor Pressure: 2.82 Psia g 60 °F Molecular weight of displaced vapors: V 69 Ib/Ib-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 V 'COLORADO 4.•c� vdrm� 3 I I:eatln4EnH�enmwn Permit Number: 15WE1443 AIRS ID Number: 123 I 91N8/ 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographic `' (Latitude/Lon 40.373914/-104.299003 Operator Mack 1D No Discharge Height Above Ground Level (' eetj, em {� low Rate ACFM ( velocity2 ft/sec 30 550 Indicate the direction of the stack outlet: (check one) O Upward O Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) ✓❑ Circular O Other (describe): O Upward with obstructing raincap Interior stack diameter (inches): 84 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC/HAPs Rating: 1.88 Type: (3) ECDs MMBtu/hr Make/Model: Cimarron/Big Hurt Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A °F Waste Gas Heat Content: 2,742 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 0.0004 MMBtu/hr D Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 l COLORADO 15, it =tenant -6f 5,1 ,1c.i Permit Number: 15WE1443 AIRS ID Number: 123 / 9DF8 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (%reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (96 reduction in emissions) PM SOX NOx CO VOC ECD 95 HAPs ECD 95 Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory 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 CO VOC 0.119 lb/bbl SSEF 37.4 1.9 46.7 2.3 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) 16 Benzene 71432 4.1E-4 lb/bbl PS Memo 14-02 321 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 3.6E-3 lb/bbl PS Memo 14-02 2,817 141 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 51 ICTCOLORADO w-r..motw M !{id,11 FIVIMAm21t Permit Number: 15WE1443 AIRS ID Number: 123 / 9DF8 / 007 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature g y (not a vendor or consultant) Date of Legally Authorized erson Marsha Sonderfan EHS Specialist Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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.qov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6 I AS'I COLORADO linittstriinricammt E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: HighPoint Operating Corp Source Name: Anschutz State 5-62-26_25 SWNW Emissions Source AIRS ID2: 123 / / Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 40222 ANSCHUTZ_STATE_5_62_26 3225CH2 ❑ 05 -123 - 40223 ANSCHUTZ_STATE_5_62_26 1724BH2 ❑ 05 -123 - 40224 ANSCHUTZ_STATE_5_62_26_1609BH2 ❑ 05 -123 - 40233 ANSCHUTZ_STATE_5_62 26_1724CH2 ❑ 05 -123 - 46080 ANSCHUTZ_STATE_5_62_26_4956C ►1 05 -123 - 46081 ANSCHUTZ_STATE_5_62_26_3240C 3240C 0 05 -123 - 46082 ANSCHUTZ_STATE_5_62_26_6457CN O 05 -123 - 46083 ANSCHUTZ_STATE_5_62_26_6457CSB r 05 -123 - 46084 ANSCHUTZ_STATE_5_62_26_3340C 3340C ►Z/ 05 -123 - 46085 ANSCHUTZ_STATE 5_62 26_4841C - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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 APCD-212-EP-StorageTank-APEN-Addendum.docx 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. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You maybe charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-2OO) 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: 15WE1439 AIRS ID Number: 123 /9DF8 /005 OCENTVD NOV % ti018 seWi: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name1: HighPoint Operating Corporation Site Name: Anschutz State 5-62-26_25 SWNW Site Location: SWNW Sec 26, T5N, R62W Mailing Address: 1099 18th St., Suite 2300 (Include Zip Code) Denver, CO 80202 Site Location Weld County: NAICS or SIC Code: Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: cdphe_corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 - Gas Venting APEN - Revision 7/2018 390393 COLORADO 1 A V I D�a�emen114Dlc. d F�N&FmH�eneM Permit Number: 15WE 1439 AIRS ID Number: 123 /9DF8/005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 O Other (describe below) -OR- ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: APEN update with new sales gas analysis. 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: Backup gas flare for 95% control of produced gas when third -party gathering system is down and unable to direct gas to sales line. Company equipment Identification No. (optional): For existing sources, operation began on: 08/15/2015 For new, modified, or reconstructed sources, the projected start-up date is: ▪ 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 Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 - Gas Venting APEN - Revision 7/2018 CI days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No COLO!@AAQ Permit Number: 15WE 1439 AIRS ID Number: 123 /9DF8/005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section A - Process Equipment Information Gas/Liquid Separator Well Head Casing Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑✓ Other Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event Description: Backup open gas flare If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ No Vent Gas Heating Value: � ,448 BTU/SCF Requested: 45 MMSCF/year Actual: 45 MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 25.4 VOC (Weight %) 37.1 Benzene (Weight %) 0.0983 Toluene (Weight %) 0.1044 Ethylbenzene (Weight %) 0.0208 Xylene (Weight %) 0.0647 n -Hexane (Weight %) 0.7010 2,2,4-Trimethylpentane (Weight %) 0.0004 Additional Required Information: O 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 will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 //y�� COLORADO 3 I AV ,aav„mac rtnnrbenri,anmect Permit Number: 15WE1439 AIRS ID Number: 123 /9DF8I005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical _Coordinates (Latitude/L.ongitude or !)V),° 40.373914/-104.299003 operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. (°F) Flow Rate fACFM) Velocity (ft/sec) Backup Gas Flare —30 Indicate the direction of the stack outlet: (check one) ❑✓ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 15WE1439 Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Make/Model: ❑✓ Combustion Device: Pollutants Controlled: Rating: Type: Emergency/Upset Process Gas 7.44 Open Flare Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: MMBtu/hr Make/Model: 95 98 Steffes Corp Dual SHP-6 Minimum Temperature: N/A Waste Gas Heat Content: 1,448 Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 0.07 MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 Permit Number: 15WE 1439 AIRS ID Number: 123 l 9DF8 /005 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (%reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO. CO VOC Flare 95 HAPs Flare 95 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant 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 40.0 mg/L AP -42 0.60 0.60 SOx 2.30E-4 lb/MMBtu AP -42 0.01 0.01 NO. 6.80E-2 lb/MMBtu AP -42 2.22 2.22 CO 3.10E-1 lb/MMBtu AP -42 10.11 10.11 VOC 24,884 lb/MMscf AP -42 560 28.00 560 28.00 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 Emissionss (pounds/year) Benzene 71432 65.9 lb/MMscf AP -42 2,966 148 Toluene 108883 70.0 lb/MMscf AP -42 3,150 157 Ethylbenzene 100414 13.9 lb/MMscf AP -42 628 31 Xylene 1330207 43.4 lb/MMscf AP -42 1,952 98 n -Hexane 110543 470.0 lb/MMscf AP -42 21,149 1,057 2,2,4- Trimethylpentane 540841 0.30 lb/MMscf AP -42 12 1 Other: 5 Requested values will become permit limitations. Requested limits) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 COLORADO IS! Z,zztrumertic:m ... Y.eW11 t2€1,41t4P9!eR{ Permit Number: 15WE1439 AIRS ID Number: 123 /9DF8/005 / 005 [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. ./U�ou ��yr�,e-cti�CL►� I''�- Q o u - lc( Signature of Legally Authorized Person (not a vendor or consultant) Date , Marsha Sonderfan EHS Specialist Name (please print) Title Check the appropriate box to request a copy of the: E✓ Draft permit prior to issuance E✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: 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.gov/cdphe/apcd AIM COLORADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I 1.12.7I`y Hello