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Home My WebLink About20191469.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 April 8, 2019 Dear Sir or Madam: RECEIVED APR 1 2 2010 WELD COUNTY COMMISSIONERS On April 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for HighPoint Operating Corporation - Critter Creek 18-4 Production Facility. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor 4.)O\`‘c'RE,vte Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer PLcTP),\Al_(3"n, Pw(3t"1 /ER IOIcY) 14/12/lot 2019-1469 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: HighPoint Operating Corporation - Critter Creek 18-4 Production Facility - Weld County Notice Period Begins: April 11, 2019 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: HighPoint Operating Corporation Facility: Critter Creek 18-4 Production Facility Oil and Gas Well Pad Lot 4 of Section 18, Township 11N, Range 63W Weld County The proposed project or activity is as follows: The Critter Creek 18-4 Production Facility serves the commingled liquid stream (containing natural gas, crude oil and produced water) from three (3) wells through 3 -phase inlet separators. HighPoint Operating Corporation has requested to permit the emissions associated with the crude oil storage, produced water storage (covered under General Permit 8) and crude oil loadout in this permit application. 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): • 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 18WE1078 and 18WE1079 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.Rov/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: James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 COLORADO 1 I grinD=Ptt Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: James Ricci Package #: 388701 Received Date: 10/9/2018" Review Start Date: 2/8/2019; Section 01- Facility Information Company Name: HighPoint Operating Corporation County AIRS ID: 123 Plant AIRS ID: 9FD6 Facility Name: Critter Creek 18-4 Production Facility Location: Lot 4 of Section 18, Township 11N, Range 63W County: Weld County Type of Facility: 'Exploration & Production WellPad What industry segment? Oil & Natural Gas Product{on &Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? 0 Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application Quadrant Particulate Matter (PM) ❑ Ozone (NOx & VOC) Section Township Range 18 11N 63 AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit 8 Issuance # Self Cert Required? Action Engineering Remarks 003 Crude Oil Tank CrudeTKs Yes . 18WE1078.CP1 1 Yes . PermitIni al Issuance Section 03 - Description of Project The Critter Creek 18-4 Production. Facility serves the commingled liquid stream (containing natural gas, crude oil and produced water) from three (3) wells through 3 -phase inlet separators. This facility is located in Weld county, North of the Ozone non -attainment area. The' inlet separators separate the fluids into individual phases (natural gas, produced water, hydrocarbon liquid). The hydrocarbon liquid (crude oil) flows first to one (1) heated flash gas separator (oil polisher), equipped with a 1.0 MMBtu/hr burner, where any entrained gases are allowed to flash from the liquid. The crude oil then flows to five (5)840 -bbl atmospheric storage tanks. Flashing, working and breathing emissions off the crude oil storage tanks are sent to the enclosed combustion devices (ECDs) HighPoint Operating Corporation has requested to permit the emissions associated with the five (5) 840 bbl crude storage tanks in this permit. Section 04 - Public Comment Requirements Is Public Comment Required? Yes" If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes 502 NOx CO VOC PM2.5 PM10 TSP HAPs 02020 ❑ 00220 DOC ❑ ❑ Is this stationary source a major source? Na If yes, explain what programs and which pollutants here SO2 NOx CO voc PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ DOD ❑ Title V Operating Permits (OP) 00000 DOD Non -Attainment New Source Review (NANSR) ❑ ❑ Crude Oil Storage Tank(s) Emissions Inventory 003 Crude Oil Tank 'Facility AlRs ID: 123' County Plant 003 Point Section 02- Equipment Description Details Detailed Emissions Unit Five (5) 840 barrelfixed roof storage vessels used to store crude oil Description: Emission Control Device 5ix (6) Leed48". Enclosed .Combustors Description: Requested Overall VOC & HAP Control 95 Efficiency ?A: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Storage Tank(s) Actual Throughput = 'Requested Permit Limit Throughput = Potential to Emit (PIE) Throughput = 382,885 Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating= 459,462 Barrels(bbl) per year Requested Monthly Throughput= 459,462. Barrels (bbl) per year 39023 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2135.5 Btu/scf Volume of waste gas emitted per BBL of , 22.0 <scf/bbl liquids produced = Pilot Waste Gas= 4015.8 MMBTU per year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit heat content of waste gas routed to combustion device = Section 04 -Emissions Factors & Methodologies Will this storage tank emit flash emissions? 22,026 MMBTU per year 25,628 MMBTU per year 25,628 MMBTU per year Pollutant Uncontrolled Controlled (Ib/bbl) Crude Oil Throughput) (Ib/bbl) " Pollutant (Crude Oil Throughput) 1.44E-04 1.01E-04 3.66E-05 1.44E-03 6.07E-07 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (lb/bbl) IMEZEIEMEMIXIBEME 6.80E-02 - (Crude Oil Throughput) 3.50E-04 Emission Factor Source Emission Factor Source AP,42Table 1.4-2 (PM10/Ph1.2.5) AP-42Tabtn1.4-2(PM10/PM.2.5( Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tans/year) (tans/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 405.6 338.0 16.9 405.6 20.3' 3445 0.1 0.1 0.1 0.1 0.1 16 0.1 0.1 0.1 0.1 0.1 16 0.9 0.7 0.7 0.9 0.9 148 4.0 3.4 3.4 4.0 4.0 675 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1323 1103 55 1323 66 931 776 39 931 47 124 103 S 124 6 337 281 14 337 17 13221 11017 551 13221 661 6 5 0 6 0 Section 06 -Regulatory Summary Analysis Regulation 3, Parts A,B Source requires a permit Regulation 7; Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation. 6, Part A, NSPS Subpart 0000 Storage Tank is notsubject to NSPS 0O00 Regulation 8, Part E, MALT Subpart HH Storage Tank is not subject to MACE HH (See regulatory applicabilityworksheet for detailed analysis) 0.001631464 0.00114766 0.000152563 0.000415082 0.016298144 6.87221E-06 Lb/bbl 82 885 Flash W&B 1.6245 0.0027 0.0019 0.0002 0.0007 0.0265 0.0000 0.1410 0.0002 0.0002 0.0000 0.0001 0.0023 0.0000 2 of S K:\PA\2018\18 W E1078.CP1.xlsm Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial and PeriodicSampling 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 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the facility being permitted? If no, the permit will contain an "initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in yS Memo 14-03. 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 Section 08 - Technical Analysis Notes A sampleof Pressurized Oil was taken at the Critter Creek 18-4 Facility on 8/24/2018 and analyzed by Alliance Source resting on 8/29/2018. The sample was flashed from:120degF & 31ps g to 93degF & 12 1psia resulting in 20.3 scf flashed gas/bbl of stock tank liquid. Base conditions were reported at 14.65 psi and 60degF. TANKS 4.0 was used assuming a RVP=8.3 to estimate VOC W&B losses. Weight percentages were used from the flash liberation analysis to estimate HAP W&B losses using the VOC W&B emissions from TANKS. Waste Gas was'calculated rising the following equation. This was able to estimate W&B waste gas since total VOC em ssinos were used. /MMBtu\ Col ( lb \ 1 SCF Gas / 1 \ Btu MMBtu Flash Gas IA J Uncontrolled VOC I\ /I x 2000 1\ /I x x379.41 x I\ /l x Heat Content (Btu) x 1(( }} yr yr tan GasMW lb •?nal VOC% \SCF/ \IO6Btu/ The stock tank liquid was analyzed resulting in a API gravity of 35.1. This was confirmed with recent COGCC Production Data. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 003 Process # SCC Code 01 Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons crude oil throughput PM2.5 0.01 0 lb/1,000 gallons crude oil throughput NOx 0.09 0 lb/1,000 gallons crude oil throughput VOC 42.0 95 lb/1,000 gallons crude oil throughput CO 0.41 0 lb/1,000 gallons crude oil throughput Benzene 0.07 95 lb/1,000 gallons crude oil throughput Toluene 0.05 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.01 95 lb/1,000 gallons crude oil throughput Xylene 0.02 95 lb/1,000 gallons crude oil throughput n -Hexane 0.69 95 lb/1,000 gallons crude oil throughput 224 TMP 0.00 95 lb/1,000 gallons crude oil throughput 3 of 5 K:\PA\2018\18W E1078.CP1.xlsm Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B-APEN and Permit Reequirements Source is In the Attainment Area T ATAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A,5ection ll.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14,03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude all storage tank capacity less than 40,000 gallons per year? 3. Aretotel facility uncontrolled VOC emissions greater than 5 TPY, NO0 greatertfian 10TPY or CO emissions greater than 10 TPY (Regulation 3, Part 6, Section 11.0.3(3 'Sourcemoiresa permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPY (Regulation 3, Part A, Section llP.l.e)? 2. Is the constructlon.ate prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answerto #2 is yes, Is the crude oil storage tank capadty less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? You hale indicated that source Is in the Attainment Area Colorado Regulation 7. Section XVII 1. Is this tank locatedate transmission/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions°of this storage tank equal to or greater than 6 tons per year VOC? 'Storage tank is subject to Regulation 7, Section XVII, B, 4.1 & C.3 Section XV11.5—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1-Emissions Control and Monitoring Provisions Section XVILC.3- Recordkeeping Requirements 5. Does the crude oitstorage tank contain only "stabiliged"liquids? If no, the following additional provisions apply. 'Storage tank Is subject to Regulation 7, Section XVII.C.2 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 90 CFR, Part 60, Subpart Kb. Standards of Performance for Volatile Organic Gould Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m') (-472 BBLs)? 2. Does the storage vessel meet the following exemption In 60.111b(d)14)? a. Does the vessel has design capacity less than or equal to 1,589.874 m°[-10,000 BBL] used for petroleum'-orcondensate stored,processed, or treated pn'orto custody transfer' as defined in 60.1116? 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 90 CFR, 60.2) afterluly 23, 1984? 4. Does the tank meet the definition of "storage vsel"a in 60.111b? 5. Does the storage vessel store a `volatile organic liquid (VOL)"sas defined in 60.1116? 6. Does the storagevessel meet any one of the following additional exemptions: a. Is thestorege vessel a pressure vessel designed to operate in excess of 204.9 kPe ["'29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ms (-950 BBL) and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110b(b))?; or c The design capacity is greater than or equal to 75 Mt (-472 BBL] but less than 151 ms ("950 BBL] andstores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.11Db(b))? No Yes Source Req Go to subgl Go to nest Source Req Continue-` Continue - Go to the n Source Is sL 951 Source issL. Storage Tat MAO Storage Tar 14. Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for WIC 160.1136 -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 crude oil storage vessel located eta facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this crude oil storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOCemissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"5 per 605430? 'Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC 960.5413 -Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 -Control Device Monitoring Requirements [Note: If a storage vessel Is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR. Part 63. Subpart MACT HH, Oil and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: e. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(')(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 toe final end user'(63.760(al(3))? 1. Is the tank located ate facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel" in 63.7617 4. Does the tank meet the definition of"storagevessel with thepotential for flash emissions° per 63.761? 5. Isthe tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 'Storage Tank is net subject to MACT HH Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774- Recordkeeping 963.775 Reporting RACT Review FACT 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 RACTrequirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis if contains may not apply to a particular sduafion 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 Cfean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language ofthe 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 °mosl" end "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. Yes Les Continue-` Storage Tar Continue-` Storage Tar EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) Ex=Q*MW* Xx/C Ex = emissions of pollutant x Q= Volumetric flow rate/volume of gas processed MW = Molecular weight of gas =SG of gas * MW of air Xx= mass fraction of x in gas C= molar volume of Ideal gas (379 scf/lb-mol) at 60F and 1 atm IMW 41.7843 Ib/Ib-mol bbl/year scf/bbl Throughput 459462 , Gas -to -Oil Ratio (GOR) 20.3 X mass fraction (%) Emission Factor (lb/bbl) Emissions (lbs/year) Oxygen/Argon 1.73 ^°"','. 3.855E-02 17711.80 CO2 ` 1.83 4.080E-02 18744.86 N2 7.97. 1.779E-01 81735.86 H2S 0.00 0.000E+00 0.00 methane 3.97 8.855E-02 40686.35 ethane 11.73 2.620E-01 120359.17 propane ..34.39. 7.680E-01 352847.90 isobutane ''5.49 1.226E-01 56308.43 n -butane 18.34 4.095E-01 188156.41 isopentane 4.04 9.014E-02 41413.70 n -pentane 4.69 _ 1.046E-01 48066.52 cyclopentane 0.43 9.708E-93 4460.52 n -Hexane 1.19 2.6476E-02 12164.87 cyclohexane :.0.26 5.767E-03 2649.84 Other hexanes 2.11 4.721E-02 21693.23 heptanes -0.73 1.626E-02 7471.47 methylcyclohexane 0.24 5.365E-03 2465.19 224-TMP 0.00 1.116E-05 5.13 Benzene 0.12 2.65031E-03 1217.72 Toluene 0.08 1.86437E-03 856.61 Ethylbenzene 0.01 2.478E-04 113.87 Xylenes 0.03 6.743E-04 309.82 C8 0.31 6.848E-03 3146.37 C9 0.05 1.058E-03 486.27 C10+ 0.27 6.102E-03 2803.73 C11 ,:"0.00 "- 0.000E+00 0.00 Total VOC Wt % 100.00 ............., iv `� 72.78 1.625E+00 373.31880 n -Hexane 224-TMP Benzene Toluene Ethylbenzene Xylenes Total GOR Conversion Check Actual Pressure (F1) 1 psia Actual Temperature (T1) 1 Rankine Actual GOR (V1) 1 cf/bbl Standard Pressure (P2) 1 psia Standard Temperature (Ti) 1 '.. Rankine Standard GOR (V2) 1 scf/bbl of Division th & Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE 1078 Issuance: 1 X HighPoint Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: General Description: Critter Creek 18-4 Production Facility 123/9FD6 Lot 4 of Section 18, Township 11N, Range 63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Crude TKs 003 Five (5) 840 barrel fixed roof storage vessels used to store crude oil Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on COLORADO Air Pollution Control Division Department of Public Health 6 Environment Page 1 of 9 rtify pli. - as r n'iuired by this permit may be obtained online at of r... ..go he/. r Fermi :,self -certification. (Regulation Number 3, Part B, n I `•G ) 3. s pe s pi : ��•wne •operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Crude TKs 003 -- 0.9 20.3 4.0 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Crude TKs 003 Enclosed Combustor VOC and HAP COLORADO Air Pollution Control Division Department of Pt,bltc Health 6 Envvonment Page 2 of 9 8. rat Number 3, Part B, II.A.4.) Process Limits owing maximum processing rates as listed below. sing rates shall be maintained by the owner or ision for inspection upon request. (Regulation Facility Equipment ID AIRS Point Process Parameter Annual Limit Crude TKs 003 Crude Oil Throughput 459,462 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.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. 12. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the COLORADO Ail Poltution Control Division Department of Pub@.o Health 6 Environment Page 3 of 9 made available to the Division upon request. This thin 90 days of the date that the storage tank 13. - sto'' : t r o •` this • - ' it 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 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (OEM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or 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. COLORADO Air Pollution Control Division Department of Public Health b Environment Page 4 of 9 the owner or operator of any facility, process, or equipent is installed, or whenever a different type of ro • r' p • aces . -xisting type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from►the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire 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 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Page 5 of 9 rmit are contested by the owner or operator, or er or operator of a source may request a hearing sion's action. 24. ion2) re•°•' s that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for crude oil storage tanks at a synthetic minor facility in the attainment zone. COLORADO Air Pollution Control Division Department of Public Health a Environment Page 6 of 9 Notes '• Pe ` it 'fi -rat tim- , his pK°g mit issuance: 1) Thp.` fee or the processing time for this permit. An invoice fo .the t fe -.l b, iss =;.d er the v>-rmit is issued. The permit holder shall pay the i `` - wi 3� • o of t voice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: //www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 003 Benzene 71432 1323 66 Toluene 108883 931 47 Ethylbenzene 100414 124 6 Xylenes 1330207 337 17 n -Hexane 110543 13221 661 2,2,4-Trimethylpentane 540841 6 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Department of Palate Health Et Drvironrnent Page 7 of 9 it are based on the following emission factors: CAS # Pollutant ncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 3.20 x 10"3 AP -42 (Flares) CO 1.46 x 10-2 VOC 1.77 x 10° 8.83 x 10"2 Flash Liberation Analysis + TANKS 4.0.9d 71432 Benzene 2.88 x 10-3 1.44 x 10-4 108883 Toluene 2.03 x 10-3 1.01 x 10-4 100414 Ethylbenzene 2.69 x 10-4 1.35 x 10-5 1330207 Xylene 7.33 x 10"4 3.66 x 10"5 110543 n -Hexane 2.88 x 10-2 1.44 x 10-3 540841 2,2,4-Trimethylpentane 1.21 x 10-5 6.07 x 10-' Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor/Major Source of: VOC, NOx, CO PSD Synthetic Source of: VOC, NOx, CO MACT HH 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/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I COLORADO Air Pollution Control Division Department of P iblic Health b Environment Page 8 of 9 art : : 'v al E i ion dard or Hazardous Air Pollutants for Source ateg CT . 63. Subp.; A - Subpart Z .'I • ` .6"" ' .11- - Sub . AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX CDPHE COLORADO Air Pollution Control Division Department of PuML Health & Environment Page 9 of 9 Colorado Air Permitting Project O Carbon Monoxide (CO) This facility is located in Weld county North.' the 07� © hon-attain rrientorea. liquid).`" PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: James Ricci 388701 10/9/20I8';j 2/8/2019, dj Section 01- Facility Information Company Name: HighPpint Operating!Corporati County AIRS ID: 123 ° Plant AIRS ID: 9F06mi Facility Name: Critter Creek 18-4 Production Facility Location: Lot 4 of Section 18, Township 11N, Range 63W County: Weld County Type of Facility: txpiprat'r rL&Prat What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Section 02 - Emissions Units In Permit Application Quadrant Particulate Matter (PM) O Ozone (NOx& VOC) Section Township Range AIRS Point# Emissions Source Type Equipment Name Emissions Control? Permit# Issuance# Self Cert Required? Action Engineering Remarks 004 ti q p rc Loadout g.V.r Yes 18WE1079.CP1 1,T a a ort>S. R Section 03 - Description of Project The Critter Creek 18-4 Production Facility serves the co 'ingl-d Iiq.: d stream (containing natural gas, crude ail and produced water) from three (3) wells through 3 -phase: T,he inlet separator .separate the fluids into individual phases (natural gas, produced water, ' The hydrocarbon liquid (crude oshjflows first to one (1) heated flash gas separator (oil polisher), equipped with a 1.0 MMBtujhr burner, where any entrained gases are allot the liquid he crude oil then flows to five (5) 840 bbl atmospheric storage tanks. Flashing , working and breathing emissions off the crude oil storage tanks are Septto the combustion devices (ECDs). Once adequate volumes are accumulated, the crude oil measured, loaded into a tank truck and sold :.Any tank vapors are ca pture¢cia 95% control efficiency. - _ - . '-, ..- H igh Point Operating corporation has requested to permit the emissions associated with the loadout of the crude oil. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Na.. a al. Section 05 -Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (P50) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs O O O O ❑ ❑ ❑ O O DID ❑ ❑ O Is this stationary source,a major source? If yes, explain what programs and which pollutants here502 Prevention of Significant Deterioration (PSD) ❑ Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) ❑ O El VOC PM2.5 PM10 TSP HAPs ❑ O O O O ❑ OOO ❑ ❑ ❑ ❑ CI Hydrocarbon Loadout Emissions Inventory 004 Liquid Loading Facility AIRs ID: County SFD6 Plant 004 Point Section 02 - Equipment Description Details Detailed Emissions Unit Truck loadout of crude Oi I by submerged fill Description: Emission Control Device Six (6) Leed 48" Enclosed Combustor Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit LimitThroughput= ?459,465.Barrels (bbl) per year Requested Monthly Throughput= 39023 Barrels (bbl) per month Potential to Emit (PTE) Volume Loaded = 95.00 382,885 ( Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = '382 SSSiBarrels (bbl) per year 459,465 (Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 2135.49 Btu/scf Volume of waste gas emitted per year= 969951 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L=12.46'5'P•M/T 1,726 MMBTU per year 2,071 MMBTU per year 2,071 MMBTU per year The stabilbed hydrocarbon liquid sample is valid for developing site specific emissions factors. Factor Meaning Value Units Source s Saturation Factor 0.6 P True Vapor Pressure 4.00111 „,,. psis From TANKS 4.0,assuming RVP:= 8.3 (Same as AP -42 Chapter 7 Table 7 1-2 -50 60 deg F) .. M Molecular Weight of Vapors 68"" lb/Ib-mol From. TANKS 4.0 assuming RVP = 8.3 (Same as AP -42 Chapter 7 Table 7.1-2) T Liquid Temperature ",,512.45': =: Rankine Liquid Bulk Temperature from TANKS 4.0 assuming Denver, CO location L Loading Losses 4.028750678 lb/1000 gallons 0.169207528 lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0:001631464 0.000276056 lb/bbl From Crude Flash Liberation (Higher than State Emissions factors so was accepted) Toluene 0.00114766 0.000194193 lb/bbl From Crude Flash. Liberation Ethylbenzene 0.000152563 2.58148E-051b/bbl From Crude Flash Liberation Xylene ,/,., 0.000415082 7.0235E-05 lb/bbl From Crude Flash Liberation n -Hexane r!r '"" 0016298144 0.002757769 lb/bbl From Crude Flash Uheration (Higher than State Emissions factors so was accepted) 224TMP rS , ' 6.87221E-06 1.16283E-06 lb/bbl From Crude Flash Liberation Pollutant Control Device Pollutant IMMINEESE Hydrocarbon Loadout Uncontrolled Controlled Oh/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) Uncontrolled (Ib/MMBtu) Uncontrolled (Ib/bbl) (Volume Loaded) (waste heat combusted) .0.0075 0.0680 Emission Factor Source Emission Factor Source 2 of 4 K:\PA\2018\18W E1079.CPi.xlsm 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 0.01 0.01 0.01 0.01 0.01 1 0.01 0.01 0.01 0.01 0.01 1 0.00 0.00 0.00 0.00 0.00 0 0,07 0.06 0.06 0.07 0.07 12 38.87 32.39 1.62 38.87 1.94 330 0.32 0.27 0.27 0.32 0,32 55 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 127 106 5 127 6 89 74 4 89 4 12 10 0 12 1 32 27 1 32 2 1267 1056 53 1267 63 1 0 0 1 0 Section 06 - Regulatory Summery Analysis Regulation 3, Parts A, B RACT- Regulation 3, Part B, Section III.D.2.a (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 Source requires a permit Site is in attainment and not subject to RACF Section 08 - Technical Analysis Notes HAP Emission factors developed using the mass fractions from the flash liberation analysis. This was accepted since it resulted in higher emi' Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 004 Process # SCC Code O3 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6) ion facto than the state approved ones. Uncontrolled Emissions Pollutant Fatter Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 16/1,000 gallons transferred SOx 0.00 0 16/1,000 gallons, transferred NOx 0.01 0 1b/1,000 gallons transferred VOC 4.0 95 lb/1,000 gallons transferred CO 0.03 0 16/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0.00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 95 lb/1,000 gallons transferred Xylene 0.00 95 lb/1,000 gallons transferred n -Hexane 0.07 95 lb/1,000 gallons transferred 224 TMP 0.00 95 lb/1,000 gallons transferred 3 of 4 K:\PA\2018\18W E1079.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)? 'Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)? 'You have indicated that source is in the Attainment Area 7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)? 'Site is in attainment and not subject to RACT Disclaimer 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. `; Yes ,Yes' WV() Yes CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1079 HighPoint Operating Corporation Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Critter Creek 18-4 Production Facility 123/9FD6 Lot 4 of Section 18, Township 11N, Range 63W Weld County Well Production Facility Equipment or activity subject to this permit: AIRS Point Equipment Description Emissions Control Description 004 Truck loadout of crude oil by submerged fill Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, l submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self - certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at COLORADO Air Pollution Control Division Department of Public health & Environment Page 1 of 9 www.colorado. • ov/cd • he t -s tific ' egu ti • Num � 4 r 3, Part B, Section III .G.2.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO 004 -- -- 1.9 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits for criteria pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) AIRS Point Control Device Pollutants Controlled 004 Enclosed Combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) COLORADO Air Pollution Control Division Department of PAL, Health 6 Dwisonmtnt Page 2 of 9 Process/Consumption Limits AIRS Point rocess Parameter nnua imit 004 Crude Oil Loaded 459,462 barrels The owner or operator shall calculate monthly process rates based on the calendar month Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 8. Crude loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) STATE AND FEDERAL REGULATORY REQUIREMENTS 9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 12. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. COLORADO Air Pollution Control Division Department of Publ`.c Health b Environrcw_nt Page 3 of 9 e. Document annual i pecti • o ` hi , halt ° and ' D 't ith a ndication of status, a descripti 13. For this controlled loading operation, the owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING & MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&tM plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or COLORADO Air Pollution Control Division Department of Pub l:c Health & Environms_nc Page 4 of 9 For volatile rgani o =,.;•u 's (VO _ nitre_-nvxides-.•urces (NO.) in ozone no _ t R = ent ;� ea it Ong le' tha 7100 tons VOC or NO. per year, a c ange in annual actua emissions o one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). 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 COLORADO Air Pollution Control Division Department nr Pubre -rearm b environment Page 5 of 9 information and with rer owner or operator's agents. It is � li • y t `5� e. lime an �operatio ��l or activity specifically identified on t e permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to HighPoint Operating Corporation for crude loadout at a synthetic minor facility in the attainment zone. COLORADO Air Pollution Control Division Department of PubLc Health b Environment Page 6 of 9 Notes to Permit Holder at the ti 1) The permit holder is require ees hesinhis peAn invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https: : / /www. colorad o. gov /pacific / cd ph e / aq cc - 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 127 6 Toluene 108883 89 4 Ethylbenzene 100414 12 1 Xylenes 1330207 32 2 n -Hexane 110543 1267 63 2,2,4-Trimethylpentane 540841 1 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. COLORADO Air Pollution Control Division Department of Pubf o Health b Environment Page 7 of 9 5) The emission levels contained Point 004: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 1.53 x 10-' AP -42 (Flares) CO 6.99 x 10-' VOC 1.69 x 10.1 8.46 x 10-3 AP -42, Chapter 5.2, Equation 1 + Engineering Estimate for HAPS Benzene 71432 2.76 x 10-4 1.38 x 10-5 Toluene 108883 1.94 x 10"4 9.71 x 10-6 Ethylbenzene 100414 2.58 x 10"5 1.29 x 10-6 Xylene 1330207 7.02 x 10-5 3.51 x 10' n -Hexane 110543 2.76 x 10-3 1.38 x 10-4 2,2,4-Trimethylpentane 540841 1.16 x 10.6 5.81 x 10-$ 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) = 4.0611 psia M (vapor molecular weight) = 68 lb/lb-mol T (temperature of liquid loaded) = 512.45 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP determined by the flash liberation of the crude oil by the VOC emission factor. Controlled emission factors are based on a enclosed combustor efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, NOx, CO PSD Synthetic Minor Source of: VOC, NOx, CO COPHE LJ COLORADO Air Pollution Control Division Department of Pubtc Health ti Environrnent Page 8 of 9 8) Full text of the Title 40, Prot can be found at the website li http://ecfr.gpoaccess.gov/ Regulations Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS 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 COLORADO Air Pollution Control Division Department of Public Health & Envvonrnent Page 9 of 9 Crude Oil Storage Tank(s) APEN Form APCD-210 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 7WEI07g- AIRS ID 123 / 9FD6 / 003 Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Critter Creek 18-4 Production Facility Site Location: Lot 4, Section 18, T11 N, R63W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.com 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. 388697 Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 1 I AV COLORADO Depmpant et Public 9!?lT9 bnvDmAnent Permit Number: AIRS ID Number: 123 / 9FD6 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action El NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit ❑ Request coverage under General Permit GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-1O6) 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: Crude Oil Tank Battery For new or reconstructed sources, the projected start-up date is: 7/12/2018 Normal Hours of Source Operation: 24 hours/day 7 days/week 52 Storage tank(s) located at: ❑✓ Exploration Et Production (EEtP) site weeks/year O Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ■ Yes SI No Are Flash Emissions anticipated from these storage tanks? p Yes • No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • 0 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No 0 ■ Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 2i �'COLORADO ( ARI!hb €nYltmmmS Permit Number: AIRS ID Number: 123 / 9FD6 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Crude Oil Throughput: Actual Annual Amount (bbl/ year) 382,885 Requested Annual Permit Limits (bbl /year) 459,462 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 35.1 degrees 0 Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 8.2 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) Crude TKs 5 4,200 7/2018 7/2018 API Number Wells Serviced by this Storage Tank or Tank Batteryb.(E&P:Sites On y) Name of Well Newly Reported Well See attached well list (Addendum) 0 0 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E8 P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.915606 / -104.482522 Operator Stack ID No. , Discharge Height Above Ground Level (feet) Temp. (°F) " Flow Rate (ACFM)' Velocity (ft/sec) ECD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) p Upward 0 Horizontal O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): ❑ Other (describe): 0 Upward with obstructing raincap 48 Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO H`NUt6 €nYV9 mm6 Permit Number: AIRS ID Number: 123 / 9FD6 / [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 0 Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs Rating: 2.93 MMBtu/hr Type: ECD Make/Model: (6) Leed 48" Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 95 98 Waste Gas Heat Content: 2,135.5 0.46 Btu/scf 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 (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 31 psig Describe the separation process between the well and the storage tanks: Crude oil from the 3 -phase inlet separators goes to the heated flash gas separators (oil polishers) and to the storage tanks. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLD R ADO eemg VOC Permit Number: AIRS ID Number: 123 / 9FD6 / [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): Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) 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 VOC mission Factor' —_ Actual Annual Emissions-- - equeste Annual Permit Emission Limit(s)5 Uncontrolled Basis lb/bbl Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year), Controlled Emissions$ (tons/year)'' Uncontrolled Emissions =- (tons/year) Controlled Emissions' (tons/year) 1.7655 Eng. Est. 337.99 16.90 405.58 20.28 NOx 0.068 Ib/MMBtu AP -42 0.75 0.87 CO 0.31 Ib/MMBtu AP -42 3.41 3.97 Chemical Name Benzene 7 -- Non -Criteria -Reportable Pollutant -Emissions -Inventory --Chernical-. -Abstract Service (CAS) Number 71432 -, Emission Factor' Actual Annual Emissions - Uncontrolled Basis 0.0029 Units lb/bbl Source (AP -42, Mfg., etc.) Eng. Est. Uncontrolled Emissions (pounds/year)-: 1,102.78 Controlled Emissions$ (pounds/year) 55.14 Toluene 108883 0.002 lb/bbl Eng. Est. 775.77 38.79 Ethylbenzene 100414 Xylene 1330207 0.0007 lb/bbl Eng. Est. 280.56 14.03 n -Hexane 110543 0.0288 lb/bbl Eng. Est. 11,013.52 550.68 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. ' Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 COLORADO 5 I AV�� ffw_Vt 4 �71YINP _ mb Permit Number: AIRS ID Number: 123 / 9FD6 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. jmuo(Lce,,-cv-1,10,40,,_ 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: 0✓ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 6I COLORADO Cepinnwn et Public R1411b Emtra mmt E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: HighPoint Operating Corporation Source Name: Critter Creek 18-4 Production Facility Emissions Source AIRS ID2: 123-9FD6 Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-44933 Critter Creek 201-1807H • 05-123-44935 Critter Creek 202-1807H • 05-123-42368 Critter Creek 537-1807H • • li • • • • O O O • 0 0 Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter NA Form APCD-212 Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014 RECEIVED OCT-92018 APCD Hydrocarbon Liquid Loading APEN at oc y 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: /3We'107c1 AIRS ID Number: 123 / 9FD6 / DOy' [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': HighPoint Operating Corporation Site Name: Critter Creek 18-4 Production Facility Site Location: Lot 4, Section 18,T11 N, R63W Mailing Address: (Include Zip Code) 1099 18th St. Suite 2300 Denver, CO 80202 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Marsha Sonderfan Phone Number: 303-312-8524 E -Mail Address2: CDPHE_Corr@hpres.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 388699 ---_--.------.._----- Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I AV COLORADO Permit Number: AIRS ID Number: 123 / 9FD6 / [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 construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Change permit limit ❑ Transfer of ownership4 0 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 a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Crude Oil Loading Company equipment Identification No. (optional): For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 07/12/2018 Will this equipment be operated in any NAAQS nonattainment area? Yes No • p Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • 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 p • If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • Fl Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No • NI Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2i AT COLORADO Department of Pattie XWNb PI•IrPormnt Permit Number: AIRS ID Number: 123 / 9FD6 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: O Condensate ❑✓ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 459,462 bbl/year This product is loaded from tanks at this facility into: (e.g. "rail tank cars" or "tank trucks") Actual Volume Loaded: tank trucks 382,885 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 A . J 4 °F True Vapor Pressure: 4.0611 Psia @ 60 ° F Molecular weight of displaced vapors: O 6 Q lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: - Requested Volume Loaded5: bbl/year - Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD 208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 1 AV COLORADO temans Public i H.16 EMim°nm! Permit Number: AIRS ID Number: 123 / 9FD6 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.915606 / -104.482522 0 erator p Stack ID Nod a Discharge Height Above Ground Level (feet) Temp ( F) Flow Rate (ACFM) Velocity (ft/sec) ECD TBD TBD TBD TBD Indicate the direction of the stack outlet: (check one) El Upward 0 Horizontal ❑ Downward o Other (describe): 0 Upward with obstructing raincap Indicate the stack opening and size: (check one) El Circular Interior stack diameter (inches): 48 O Other (describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC, HAPs Rating: 0.24 Type: ECD MMBtu/hr Make/Model: Leed 48" Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: °F Waste Gas Heat Content: 2,135.5 Btu/scf Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.46 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4IAY COLORADO Gepaneeau of Palle Meant F B rOrsmsnen! Chemical Name Benzene Permit Number: AIRS ID Number: 123 / 9FD6 / [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 PM Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) SOX NO. CO VOC ECD 95% HAPs ECD 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane o 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 Pollutant __..Criteria- Pollutant : Emissions Inventory _ mission Factor Uncontrolled" Ib/MMBtu Source (AP -42,. Mfg-, etc.) Actual Annual EMissioris77 Uncontrolled- Emissions .. (tons/year) Controlled • Emissions6 (tons/year) Requested AnnualPermit Emission Limit(s)5 Uncontrolled Emissions (tons/year) Controlled 1 Emissions, (tons/year) PM SOx NO. 0.068 AP -42 0.06 0.07 CO 0.31 Ib/MMBtu AP -42 0.27 0.32 VOC 0.16921 lb/bbl Eng. Est. 32.39 1.62 38.87 1.94 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis lb/bbl Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) 71432 Toluene 108883 Ethylbenzene Xylene n -Hexane 100414 1330207 110543 0.00276 Eng. Est. 1055.6 52.8 2,2,4- Trimethylpentane Other: 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5i AY COLORADO rzwem mdwtuc Permit Number: AIRS ID Number: 123 / 9FD6 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant. Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. JAAA/444-, tit 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: 0✓ Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6I AY COLORADO 5€+AM HWmmmmt Hello