HomeMy WebLinkAbout20194465.tiff COLORADO
Department of Public
GOPt€ Health Et Environment RECEIVED
OCT 072019
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
October 2, 2019
Dear Sir or Madam:
On October 3, 2019, the Air Pollution Control Division will begin a 30-day public notice period for
Crestone Peak Resources Operating, LLC - Davis 9H-G266. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
/
7""--
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
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director }
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(O/114 OG(Tr1) 2019-4465
1O/o Oil
„rO:41. Air Pollution Control Division
HE Notice of a Proposed Project or Activity Warranting Public
CDPHE
cComment
Website Title: Crestone Peak Resources Operating, LLC - Davis 9H-G266 - Weld County
Notice Period Begins: October 3, 2019
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: Crestone Peak Resources Operating, LLC
Facility: Davis 9H-G266
Exploration Et Production Well Pad
SWNE Section 9, T2N, R66W
Weld County
The proposed project or activity is as follows: Crestone Peark Resources requested that the name of this
facility be modified from "Davis 1A, 1B, 1C Horizontal" to "Davis 9H-G266". The facility has been newly
constructed but was determined to be collocated with the previous facility and contains a total of 20 wells
that flow to these processes. The facility has GP01 and GP05 coverage. For this project, condensate loadout
volume increased, and the facility added a LP separator venting and fugitives point. The facility is synthetic
minor for VOC, n-hexane, and total HAPs.
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 Permits 13WE1750, 19WE0194,
and 19WE0195 have been filed with the Weld County Clerk's office. A copy of the draft permit and the
Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-
permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
1 °FHe Health @ Environment
,..t COLORADO
„--- Air Pollution Control Division
/ry n
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 13WE 1750 Issuance: 3
Date issued:
Issued to: Crestone Peak Resources Operating, LLC
Facility Name: Davis 9H-G266
Plant AIRS ID: 123/9B2A
Physical Location: SWNE SEC 9 T2N R66W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control -
Equipment Description
ID' Point Description
LOAD-1 003 Truck loadout of condensate by Enclosed Combustion
submerged fill. Device
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B,
Section III.G.5.)
Page 1 of 10
-r , COLORADO
Air Pollution Control Division
iii 4.4v0
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation
Number 3, Part B, Section II.A.4)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO. VOC CO Type
LOAD-1 003 --- --- 5.3 --- Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field'office with
site responsibility for Division review.
3. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
4. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants Controlled
ID Point
LOAD-1 003 Enclosed Combustion Device VOC and HAP
PROCESS LIMITATIONS AND RECORDS
5. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Reference: Regulation Number 3, Part
B, II.A.4)
Page 2 of 10
aHFK9M COLORADO
Air Pollution Control Division
COFHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Process/Consumption Limits
Equipment AIRS Process Parameter Annual Limit
ID Point
LOAD-1 003 Condensate Loaded 1,533,000 barrels
The owner or operator must calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
6. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must
allow or cause emissions into the atmosphere of any air pollutant which is in excess,of 30%
,opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.),,
7. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
8. This source is located in an ozone non-attainment or attainment-maintenance area and is
subject to the Reasonably Available Control Technology (RACT) requirements of Regulation
Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged
fill and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, ',III.D.2)
9. All hydrocarbon liquid loading operations,regardless of size, must be designed, operated and
maintained so as to minimize leakage of volatile organic,compounds to the atmosphere to the
maximum extent practicable.
10. The owner or operator must follow loading procedures that minimize the leakage of VOCs to
the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E):
a. The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loading and unloading. The inspections must occur at least monthly.
Each inspection must be documented in a log available to the Division on request.
b. All compartment hatches at the facility (including thief hatches) must be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers must be weighted and properly seated.
Page 3 of 10
je .M,f COLORADO
.4:40—J Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
d. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs must be set to release at a pressure that will ensure flashing, working
and breathing losses are not vented through the PRD under normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
11. For this controlled loading operation, the owner or operator must follow loading procedures
that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference:
Regulation Number 3, Part B, III.E):
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back-pressure less than the pressure
relief valve setting of transport vehicles.
OPERATING £t MAINTENANCE REQUIREMENTS
12. Upon startup of these points,the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
13. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
14. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
15. All previous versions of this permit are cancelled upon issuance of this permit.
16. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
Page 4 of 10
,. , COLORADO
4 Air Pollution Control Division
`3=1.11 Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a
change in annual actual emissions of one(1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted.
For any non-criteria reportable pollutant:
If the emissions increase by 50%or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
18. 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.
19. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
Page 5 of 10
, »,.. COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
20. 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.
21. 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.
22. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
23. 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.
24. 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:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 November 8, 2013 Issued to Encana Oil a Gas (USA), Inc.
Issuance 2 January 21, 2015 Issued to Encana Oil a Gas (USA) Inc.
Increased throughput and emission limits -
issued as final approval.
Issuance 3 This Issuance Issued to Crestone Peak Resources Operating,
Page 6 of 10
C40r COLORADO
_+0 Air Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
LLC
Increased throughput, added control device,
decreased emission limits.
Corrected HAP emission factors.
Page 7 of 10
C4Cxr COLORADO
Air Pollution Control Division
i
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 1,999 100
Toluene 108883 3,530 177
003 Ethylbenzene 100414 149 7
Xylenes 1330207 1,553 28
n-Hexane 110543 4,955 248
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
. . COLORADO
IP NV-71 Air Pollution Control Division
W
Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors lb/bbl
lb/bbl
NOx 2.22E-04 2.22E-04 AP-42,
CO 9.78E-04 9.78E-04 Chapter 13.5
VOC 1.39E-01 6.95E-03 AP-42, Chapter
5.2, Equation 1
Benzene 71432 1.30E-03 6.52E-05 AP-42, Chapter
Toluene 108883 2.30E-03 1.15E-04 5.2, Equation 1
Ethylbenzene 100414 9.71E-05 4.86E-06 Et
Xylene 1330207 1.01 E-03 5.06E-05 Site-Specific
n-Hexane 110543 3.23E-03 1.62E-04 HAP Weight
Fraction
,
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) = 4.8 psia
M (vapor molecular weight) = 47.2 lb/lb-mol
T (temperature of liquid loaded) = 512 °R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated
by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Controlled emission factors are based on a flare efficiency of 95% and a collection,efficiency of
100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, n-hexane
PSD True Minor Source
NANSR Synthetic Minor Source of: VOC
Page 9 of 10
COLORADO
Air Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A- Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Cr-:x- COLORADO
Air Pollution Control Division
CDPNk
Department of Pubttc Health b Enuitonmenk
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 1 9WE01 94 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC.
Facility Name: Davis 9H-G266
Plant AIRS ID: 123/9B2A
Physical Location: SWNE SEC 9 T2N R66W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
Buffer 004 Low Pressure Separator Enclosed Combustion
Device
This permit is granted subject to all ;rules and regulations; of the' Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act(C.R.S. 25-7-101 et seq), to this
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, b.y submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit shall be
demonstrated to the Division. It is the owner or operators' responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 8
COLORADO
44444,ler Aix Pollution_Control Division
BP'E<.
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit shall expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
4. The operator shall 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 AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
Buffer 004 -- --- 5.0 1.2 Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Page 2 of 8
COLORADO
1p Air Pollution Control Division
Department of Pubtic Health El Envnronment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Emissions from the Low Pressure
Buffer 004 Separator are routed to an Enclosed VOC and HAP
Combustion Device during Vapor Recovery
Unit (VRU) downtime
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
Buffer 004 Liquids Throughput 28,364 bbl/yr
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder shall calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
10. The owner or operator shalt !continuously, monitor and record Vapor Recovery Unit (VRU)
downtime while emissions are routed to the control device.
11. The owner or operator must use monthly VRU downtime records, monthly condensate/crude oil
throughput records, calculation methods detailed in the O&M;Plan, and the emission factors
established in the Notes to Permit Holder to demonstrate compliance with the process and
emissions limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.17; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the following schedule:
Page 3 of 8
-s•rCe_ COLORADO
Air Pollution Control Division
eDPHE.
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only).
On or after August 1, 2014, gas coming off a separator, produced during normal operation from
any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either
be routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING Et MAINTENANCE REQUIREMENTS
16. Upon,startup of these points, the owner or operator shall follow the most recent operating and
maintenance (OFtM) 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 OttM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner or operator 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.A17)
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
Page 4 of 8
C _ COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
Page 5 of 8
COLORADO
Air Pollution Control Division
GOPHE
" Department ofPub is Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit
and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civit or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC
Page 6 of 8
COLORADO
10,14,40,41 Air Pollution.Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon, as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part',Il.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Facility Uncontrolled Controlled
Equipment AIRS Pollutant CAS E# Emissions Emissions
ID Point (lb/yr) (lb/yr)
Benzene 71432 349 17
Buffer 004
n-Hexane 11O543 3,679
' 184',"
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates
above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on
the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
Uncontrolled Controlled
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/bbl) (lb/bbl)
NOx 0.0240 0.0240 AP-42, Chapter
CO O.0846 0.0846 13.5
VOC 7.0159 0.3508 Site-Specific
71432 Benzene 0.0123 6.15E-04 Extended Gas
Sample Analysis
110543 n-Hexane 0.1297 6.485E-03 (Taken
02/12/2019)
Page 7 of 8
- ,, COLORADO
C..
+�'_% Air Pollution Control Division
�f Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: The controlled emissions factors for this point are based on the enclosed combustion
device control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN shall be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, n-Hexane
NANSR Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
htto://www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A- Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A- Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 8 of 8
:� COLORADO
4 Air Pollution Control Division
CDPHE
C.
C Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0195 Issuance: 1
Date issued:
Issued to: Crestone Peak Resources Operating, LLC.
Facility Name: Davis 9H-G266
Plant AIRS ID: 123/9B2A
Physical Location: SWNE Section 9 T2N R66W
County: Weld County
Description: well Production Facility
Equipment or activity subject to this permit:
Facility AIRS
Equipment Description
ID Point
FUG 005 Equipment Leaks (fugitive VOCs) from a natural gas
exploration and production well pad.facility.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days
of the latter of commencement of operation or issuance of this permit, by submitting a
Notice of Startup form to the Division. 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 No. 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. (Reference: Regulation No. 3, Part B, III.G.2).
3. 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.
(Reference: Regulation No. 3, Part B, Section III.E.)
Page 1 of 8
COLORADO
Air Pollution Control Division
��ii+1� Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Facility AIRS Tons per Year
Equipment ID Point VOC Emission Type
FUG 005 1.1 Fugitive
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
Facility-wide emissions of each individual hazardous air pollutant shall be Less than 8.0 tpy.
Facility-wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
Compliance with the annual limits shall be determined by recording the facility's annual criteria
pollutant emissions, (including all HAPs above the de-minimus reporting level) from each
emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-
month total shall be calculated based on the previous twelve months' data. The permit holder
shall calculate emissions each month and keep a compliance record on site or at a local field
office with site responsibility, for Division review. This rolling twelve-month total shall apply
to all permitted emission units, requiring an APEN, at this facility.
6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
7. The operator shall calculate actual emissions from this emissions point based on representative
component counts for the facility with the most recent gas analysis, as required in the
Compliance Testing and Sampling section of this permit. The operator shall maintain records
of the results of component counts and sampling events used to calculate actual emissions and
the dates that these counts and events were completed. These records shall be provided to the
Division upon request.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive
minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall
have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. 8 4.)
9. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
10. This source is subject to Regulation No. 7, Section XII.C General Provisions (State only
enforceable). All condensate collection, storage, processing and handling operations,
regardless of size, shall be designed, operated and maintained so as to minimize leakage of
Page 2 of 8
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
volatile organic compounds to the atmosphere to the maximum extent practicable. The
operator shall comply with all applicable requirements of Section XII.
11. Minor sources in designated nonattainment or attainment/maintenance areas that are
otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply
Reasonably Available Control Technology for the pollutants for which the area is nonattainment
or attainment/maintenance (Reference: Regulation No. 3, Part B, III.D.2.a).
12. Fugitive component leaks at this well production facility are subject to the Leak Detection and
Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re-
monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition,
the operator shall comply with the General Provisions contained in Regulation 7, Section
XVII.B.1.
OPERATING £t MAINTENANCE REQUIREMENTS
13. This source is not required to follow a Division-approved operating and maintenance plan.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
14. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, the operator shall complete a hard count of components at the source
and establish the number of components that are`:operated in "heavy liquid service", "light
liquid service", ""water/oil service" and "gas service". The operator shall submit the results to
the Division as part of the self-certification process to ensure compliance with emissions limits.
Periodic Testing Requirements
15. On an annual`..basis, the owner or operator shalt complete an extended gas analysis of gas
samples that is representative of"volatile organic compounds(VOC) and hazardous air pollutants
(HAP) that may be released as fugitive emissions. This extended gas analysis shall be used in
the compliance demonstration as required in the Emission Limits and Records section of this
permit.
ADDITIONAL REQUIREMENTS
16. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
Page 3 of 8
ro,. COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or activity;
or
c. Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
17. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source shall not exceed the Federal program threshold until a
permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
18. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation No. 3, Part B, SectionII.B upon a request for transfer of ownership and the submittal
of a revised APEN and the required fee.
19. 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)0) C.R.S. and AQCC Regulation No. 3, Part B, Section III.G. Final authorization cannot
be granted until the operation or activity commences and has been verified by the APCD as
conforming in all respects with the conditions of the permit. Once self-certification of all points
has been reviewed and approved by the Division, it will provide written documentation of such
final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self-Certify for Final Authorization section of this permit.
20. 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.
21. 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.
22. 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
Page 4 of 8
z COLORADO
Air Pollution Control Division
Ite
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
23. 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.
24. 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:
Lauraleigh Lakocy
Permit Engineer
Permit History
-" 'Issuance Date Description
Issuance''1 This Issuance Issued to Crestone Peak Resources Operating,
LLC
Page 5 of 8
C - I COLORADO
le X°I Air Pollution Control Division
CDPME
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder shall pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit
(Reference: Regulation No. 3, Part A, Section VI.B.)
2) The 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://vovw.colorado.gov/pacific/cdphe/agcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based;upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
Uncontrolle Are the
d Emission emissions
AIRS Rate reportable
Point Pollutant CAS# BIN (lb/yr) ?
Benzene 71432 A 8 No
Toluene 108883 C 37 ' No
005 Ethylbenzene 100414 C 4 No
Xylenes 1330207 C 48 No
n-Hexane 110543 C 69 No
5) The emission levels contained in this permit are based on the following emission factors:
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 5,428 289 2,884 40
Flanges 934 0 1,050 0
Open-ended Lines 1,908 570 737 5
Pump Seals 0 --- 1 0
Valves 1,810 46 1,620 13
Other* 0 0 0 0
VOC Content (wt. 0.2766 1.00 1.00 1.00
fraction)
Page 6 of 8
r: COLORADO
Air Pollution Control Division
COPHE
Department of Public Health B Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Benzene Content (wt. 0.0008 0.0041 0.0041 0.0041
fraction)
Toluene Content (wt. 0.0040 0.0177 0.0177 0.0177
fraction)
Ethylbenzene (wt. 0.0005 0.0020 0.0020 0.0020
fraction)
Xylenes Content (wt. 0.0045 0.0240 0.0240 0.0240
fraction)
n-hexane Content 0.0068 0.0334 0.0334 0.0334
(wt. fraction)
2,2,4-
Trimethylpentane 0.000006 0.0005 0.0005 0.0005
(wt. fraction)
*Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms,
drains,dump arms, hatches, instrument meters, polish rods and vents
TOC Emission Factors (kg/hr-component):
Component Gas Service Heavy Oil Light Oil Water/Oil
Service
Connectors 1.0E-05 ' 7.5E-06 9.7E-06 1.0E-05
Flanges 5.7E-06 3.9E-07 2.4E-06 2.9E-06'.
Open-ended Lines 1.5E-05 7.2E-06 1.4E-05 3.5E-06
Pump Seals 3.5E-04 NA 5.1E-04 2.4E-05
Valves 2.5E-05 8.4E-06 1.9E-05 9.7E-06
Other 1.2E-04 3.2E-05 1.1E-04 5.9E-05!
Source: EPA-453/R95-017, Table 2-8
Compliance with emissions limits in this permit will be demonstrated by using the TOC emission
factors listed in the table above with representative component counts, multiplied by the VOC
content from the most recent gas analysis.
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 Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, n-hexane
Page 7 of 8
C -::: COLORADO
10 41-044 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
NANSR Synthetic Minor Source of: VOC
PSD True Minor Source
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A- Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this
permit may be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-
certification.
Page 8 of 8
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer: Lauraleigh,Eaocy
Package It: 393537 `
•
Received Date: 2/22/2019g.wyy „
Review Start Date: 4/16/2019;"?:^:,;,i,C;.:,; ft'is)
Section 01-Facility Information
Company Name: Creston Peak Resources Operating,LLC Quadrant Section Township Range
County AIRS ID: 123 SWNE 9 2N 65 `- •
-
PlantAIRS ID: 9B24 1,g
Facility Name: Davis 9H-G266
Physical
Address/Location: SWNE quadrant of Section 9,Township ON,Range 65W
County: IWeldCounty
Type of Facility: B�tplorafran�Frradu n Well iH 3 i \ s �y
What industry segment? ti{ .N txratCat P•,,
Is this facility located in a NAAQS non attainment area?
If yes,for what pollutant? ❑ Carbon Monoxide(CO) El Particulate Matter(PM) ✓ Ozone(NOx&VOC)
• Section 02-Emissions Units In Permit Application
Emissions Self Cert Engineering
AIRs Point# Emissions Source Type Equipment Name permit# Issuance# Action
Control? Required? Remarks
� Increased
. ws r �y'Ogi �' �� �- „� 'v r3 t' -) ₹ throughput,
o�
\>c Permit added control
₹{in \f r . LOACt 1, No • - 13WE1750,:. 3. P
� �� �;. �.. ,/...ir�ifica₹ion device
li rf - r3 ��'. Permit Initial
D0�� i�es'`epArAthithth pet spew) �Y gw�, ., Buffer Yes 19WE0194"t' 3 � t:l s� issuance
Pfinfrl �/ f PeimitInitial
eleffielaCt
sifireser 005 •.• -aF"Yf Nde( omp FUG No 19WEa19s 1 , '•" Issuance
.
,.
Section 03-Description of Project
Crestgga•PearkResburces:reguested'thatthename of this facility be modified trcim"Catias lw 13,1C Horizontal to"Davis 5H-6266" The has been newly constructed
but was'deeterrrnneclto be collocated withltheprev ous facility and contains a total of 20 wells that`'row to these processes.The GP61 perrut was updated to a stew site
3 specific"emt5sio'14 ctor and thr r#ghkiiwtwas increa.eo the GP05 was.renewed(previously below thresholds),condensate Ice clout volume increased,and the faciiity.added a
t LPseparateruetdingandfugttl trt Addtt4ionally there wwere 9-new compressorstht were added at the facititythat were processed under the XPprugram due to`' •
horsepcwer kk a s 4-
a Thefiaccrt ft ) Ogg, OC exa P. a d total HAPs.The tot l VOC emissions at this e are 62.?tpy(permitted 59.3 toy). �
Section 04-Public Comment Requirements
Is Public Comment Required? Yeu��
If yes,why? eelu�'an 5y •ic;Ntilrvn Permit „as,., �,.._a,., l .;`� :;z .
Section 05-Ambient Air Impact Analysis Requirement
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-WideStationary Source Classification
Is this stationary source a true minor? '" a u//•No 1
Is this stationary source a synthetic minor? w,?w a�'s•••.N., __
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(P5D)Title V Operating Permits(OP) _ O LI
Non-Attainment New Source Review(NANSR) ✓ •
Is this stationary source a major source? a
If yes,explain what programs and which pollutants here 502 NOx CO VOC PM2.5 PM10 TSP HAPs
PTree V Operating
of rating t Deterioration(P50) - ❑ ❑
Title V Operating Permits(OP)
Non-Attainment New Source Review(NANSR)
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
Facility AIRS ID: County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit TnrckLoadont of Conifensatefmmiaoks
Description: ._.,, _. _... .. _...
Emission Control Devi '
Device
Enslnsad'crtmhdsilatrDeaiea
Description:
Is this loadout controlled? r
Collection Efficiency: -'f:(!lq 0 ;,I
Control Efficiency: 95
Requested Overall VOC&HAP Control Efficiency%: 95.00
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= ..i'::::,.6',323=Barrels(Will per year ActualVolume Loaded While Emissions Controls Operating= 6,923:Barrels(bbl)per year
Requested Permit Limit Throughput= ,x3300#1,Barrels(bbl)per year Requested Monthly Throughput= 130200 Barrels(bbl)per month
Padentlal to Emit(PTE)Volume Loaded= y1y035 fi Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2544 Btu/scf
Volume of waste gas emitted per year= 1700704 scf/year
Actual heat content of waste gas routed to combustion device= 20 MMBTU per year
Requested heat content of waste gas routed to combustion device= 4,347 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 5,217 MMBTU per year
Section 04-Emissions Factors&Methodologies _
Does the company use the state default emissions factors to estimate emissions, Nu
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the f cility
being permitted?
Loading Loss Equation
L=12.46*S*P*M/T
Factor Meaning Value Units Source
S Saturation Factor 0.6 tliti' g �b "-C� " ),
m,...,. k�//AP- �Ctsir,�„'.'E�, rlset8ad;ixead-eR f5ed6 �
P True Vapor Pressure _'.psia TVR"of Gonohoo i?yP YO
M Molecular Weight of Vapors '47.7`. lb/Ih-mol <-:AP-42 Chapter?
7 Liquid Temperature :532.451,•-:Rankine - Standard Operating Conditions
Loading Losses 3.303124230 lb/3000 gallons
0..1387312.1E Ib/bbl
Component Mass Fraction Emission Factor Units Source
Benzene ?0.0054 ` ll,0111304lt?3 lb/bbl 3aa5pl¢IAnalysis from Initial Permitting APPlienti0n(2013) •
Toluene .•:x'10.0156,.- 0,002802030 lb/bbl ••rSampleyAnalysis from initial Permitting Application 12011)
Ethylbenzene '-`00002 8,71119E-05 lb/bbl "SaalplerAnalysis from,lnitiai'Permitting Application(733)
Xylene --o,0073,c 0.00101.27351b/bbl 5aalpleAnalysla from Initial Permitting Application(2013)
n-Hexane .:.0.0233'' 0.003232437 lb/bbl Sample Analysis fromInitial Permitting-Application(2013)
224TMP - .. 0lb/bbl Sample Analysis:from initial Permitting Application(2613)
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Pollutant (lb/bbl) (Ib/bbl) Emission Factor Source
(Volume
(Volume Loaded) Loaded)
VOC 1.39E-01 6.94€-03 SIt Sp dill 0yCrfapter AE ;„o6.a. "
_ Benzene 1,30E-03 6.52E-0S SiSeSpocWc AtP Ghaptmo5.ZEgtEal3dw".£k°
Toluene 2.30E-Q3 1.15E-04
Ethylbenzene 9.71E-QS 4,86€0613 Ts ras l'
Xylene L01E-03 5.06E-05 '"ttSgiWi5d-rtt r (Fp:Y
n-Hexane 3.230:03 1.62£04
224 TMP 0.00E:t70 0,00E i00
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(Volume
(Waste heat combusted) Loaded)
PM10 ..100075 2,11E-OS "f'- &31ffe „,2'5`
PM2.5 0`oo75 2.11€O5
BOB fF.O006 1.67E O6 AL'-42,32618 flit //�.t
NOx ,:)}0686 -.-' 1.035-04 - gfKr,,(a Elaeas filg7 F
---
CO 0.3100. :1.'n 0.704-04 „',Ilsdustirai€lsreo)CO,) >,
2 of 12 K:\PA\2013\13WE1750.CP3
Hydrocarbon Loadout Emissions Inventory
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) tons/year) Ohs/month)
PM10 0.02 0,00 0.00 0.52 0.52 3
PM2,5 0.02 0.00 0.00 0.02 0,02 3 -
SOx 0,00 0,110 0.00 0,00 0.00 0
NOx 0.18 0.00 0.00 0.15 0.15 25
VOC 127,00 0,48 0.02 106,34 5,32 000
Co 0.81 0.00 0,00 0.67 0.67 114
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/yeerl (Ibs/year) (Ihs/year) (Ibs/year) (Ibs/year)
Benzene 2399 9 0 1999 100
Toluene 4206 16 1 3530 177
Ethylbenzene 179 1 0 140 7
Xylene 1853 7 0 1553 78
n-Hexane 5046 22 1 4955 246
224 TMP II 0 0 0 0
Section 06-Regulatgry Summary Analysis
Regulation 3,Parts A,B Not enough information
RACT-Regulation 3,Part B,Section III.D.2.a The umlaut most operate with submerged fill and loademf emissions most be routed to flare to Satisfy 0410.
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
F ry
Does the company request a control device efficiency greater than 95%for a flare or combustion device? O�
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
rotes Emission factors.tfaue not been updated since inmal issuance of permit.Source hasonty requestedta.decrease in thethrougttputand associated emissions.
Caicutatiopsabove arebuvedopthesample provided with the original appficatfan.Itappears that the ml.:ionfectnrswere not appropriatelycarnedformard,so this issuance will'deflne the emission factors for all
E HAPs �:::.>' .'
Section 09-Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point It Process to SCC Code Pollutant Factor Control% Units
003 01 4-06-001-32 Crude Oil:Submerged Loading Normal Service(S.0.6) PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
500 0,00 0 lb/1,000 gallons transferred
NOx 0.00 0 lb/1,000 gallons transferred
VOC 3.3 95 lb/1,000 gallons transferred
CO 0,02 0 lb/1,000 gallons transferred
Benzene 0.03 95 lb/1,000 gallons transferred
Toluene 0.05 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.02 95 lb/1,000 gallons transferred
n-Hexane 0.05 55 lb/1,000 gallons transferred
224 TMP 0.00 05 lb/1,000 gallons transferred
3 of 12 K:\PA\2013\13 W E1750.CP3
•
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Re:.laden 3 Parts A and B-APEN and Permit Requirements
• (source is in the Non-Atteltuno mt.Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section liD.l.a)?
2- Is the loadout located at an exploration and production site(e.g.,well pad((Regulation 3,Part B,Section 11.0.1.11?
3- Is the loadout operation loading less than 10,000 gallons(238Mks)of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbis per year of condensate vla 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 lO TPY(Regulation 3,Part B,Section 11.D.3)7 Q
Ins have lndlcnted shot source is in the"Jan-Antoinment Aran
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than l TPY(Regulation 5,Part A,Section Il D.1.a)? Yee ,S Go to next
• 2. Is the loadout located at an exploration and production site(e.g.,well pad)(Regulation 3,Part B,Section IID.1.1)? • MS):"c Go to the n
3. Is the loadout operation loading less than 10,000 gallons(238 BBLs(of crude oil per day on an annual average basis? h ,
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? ` "'.Go to next
5. N the loadout operation loading less than 16,308 bbls per year of condensate',Ia'submerged fill procedure? Dlr1").`\'Ii Go to next,
•
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 11.0.2)7 Yee>. The Math.
INat enough information
7. PACT-Are uncontrolled VOC emissions from the loadout operation greater than 20 spy(Regulation 3,Part 8,Section l®-0.2.a)? Yes .y%The landau
(The loadout must operate with submerged MI and loadout emissions must he routed to Mare to serial's RACT.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is
not a rule or regulation,and the analysis It contains may not apply to a particular situation based upon the Individual facts and circumstances.This document does not change or substitute for any law,
regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and Ore 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 recommendation.Mandatory terminology such as}mat"and'required"are intended to describe centrally 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.
Separator Venting Emissions Inventory
•
004 Separator Venting
'Facility AIRs ID:
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Description: LouwPressure$eparatorkentsgrlthgeVHUJsaru-gflloe '::_° Mh "•e' ,,,,,,
Emission Control Device Description: Enclosed Combustion Device _
Requested Overall VOC&HAP Control Efficiency%:
Limited Process Parameter tk ,u
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= Barrels(hbl)per year
Requested Permit Limit Throughput= .1100;364;x:Barrels(bbl)per year Requested Monthly Throughput= 2409 MMscf per month
Potential to Emit(PTE)Throughput= 20,354 Barrels(bbl)per year
Process Control(Recycling)
Equipped with a VRU:WSW
y
Is VRU process equipment:figN Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed(i.e.waste gas volume that is routed to the flare)
Secondary Emissions-Combustion Device(s)for Air Pollution Control
Separator Gas Heating Value: .1423__Btu/scf
Volume of waste gas emitted per BBL of "From ProMax simulation
liquids throughput:
Section 04-Emissions Factors&Methodologies
Description
.�S'ilt ign*1.�,*13 d k, ;,, hN .xi ,4.. :.,, g' :gin a��, W,u� ``0 �.....;.R`3 �
t;t jr- h s arf44al Sk was bas d nao stnended ga analy�s of the Bo fer House fiasr a amps taken 2/32/.2039 wttfi a Sample pressuro'oh 5,4yfl0 and sample 60 operatuW.6,. yu. 4}t<i�
MW ---34-,1200 lb/lb-tool Displacement Equation
Ex=4'MW•Xx/C
Weight%
Helium/Oxygen/Argon
CO2 ,;;2;50
N2 '1:05
methane
ethane •1B.UB
propane L;:54.35
isobutane
n-butane
isopentane ..4,30
n-pentane ,,.,.T.,n:S.SH
cyclopentane
n-Hexane "%1.1'
cyclohexane �r5.20
Other hexanes
heptanes 0.43:
methylcyclahexane • 013'
224-TMP b,Qi3.
Benzene
Toluene Ethylbenzene
Xylenes
C8+Heavies __. `^ ".:.0r>•:'
Total 100.00
VOCWt% 50.15
ENIMIESEIMIE Separator Venting
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Liquid Throughput) (Liquid Throughput)
Emmirell 0.0000 0.0000
® 0.0045
® 0.0000
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) 16/bbl Emission Factor Source
(Waste Heat
Combusted) (Gas Throughput)
0.0075 0.902 REIVP7S
O:QQo5 0.000
on680
0.3100 F,.i s f
5 of 12 K:\PA\2013\13WE1750.CP3
Separator Venting Emissions Inventory
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month)
PM10 0.03 0.03 0.03 0,03 0.03 4
PM2.5 0.03 0.03 0.03 0.03 0.03 4
500 0.00 0.00 0.00 0.00 0.00 0
NOx 0.24 0.24 0.24 0.24 0.24 41
VOC 99.50 99.50 4.07 99.50 4.97 045
CO 1.1.0 1.1.0 1,1.0 1,111 1,:111 '185
• Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (Ibs/yearl (Ibs/year) (lbs/year) (Ibs/year)
Benzene 349 349 17 349 17
Toluene 160 100 8 160 8
Ethylbenzene 3 3 0 3 0
Xylene 75 25 .1. 25 .1.
n-Hexane 3679 3679 1114 3679 184
224 TM P 1 1 0 1 0
Section O6-Rea elatog.Rummary Analysis
Regulation 3,Parts A,B Source requires a permit
Regulation 7,Section XVII.B,G Source is subject to Regulation 0,Section 00₹1.8.3,0
Regulation 7,Section XVII.B.2.e the control device for this separator is not subject to Regulation 7,Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
It,have indicated above the monitored process parameter Is Liquid Througput.The foilewing question does not require an answer,
s r r I rr .dc ..4 , r wY/ .,.
yrN,
/ / Yf" r l
„ u
/ l .
0� 1 1 Alleglw,4411(f*
5
' �f,.
.: • /
„lorm / �, /„
NI :y ,,:
�y .. Y ,. .mil „'ii/ii ., f
% N
Using Liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized liquid sample(Sampled upstream of the
equipment covered under this AIRs ID)and process simulation to estimate emissions? 11.e•-
This sample should have been collected within one year of the application received date.However,if the facility has not been modified(e.g.,
no new wells brought on-line),then it maybe appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Compliance"testing requirement to collect a site-specific liquid sample and conduct an emission
factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
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
an inlet and outlet concentration sampling
6 of 12 K:\PA\2013\13WE1750.CP3
Separator Venting Emissions Inventory
Section 00-Technical Analysis Notes
Thefac:tty samplodthe gas vented frontthe Buffer house and usingthe extended gas analysis used the displacement e'quation(asshawn ahove)to calculate
aly emissldns. •• �` a '' et aAte^-
ss
Section 09-Inventory SCC Coding and Emissions Factors
Uncontrolled
Em€ssions
AIRS Point q Process q SCC Code Pollutant Factor Control% Units
004 01 _ 3-10-001-29 Oil 8 Gas Production:Gaslliquid separation PM70 1,65 r,00000
EhjlpGOhhl
PM2.5 1.06 0 IbJ1000bbl
SOz 0.15 0 €bfip00hb€-
NOz 16x,94 0 €b/1000hb€
VOC. 7015;&9 95 Ibfl05Gbb€
CO 77.21 0 €h/1000bhl
Benzene 12.13 95 I€xf1000bb€
Toluene 5.65 95 €b/10000bl
Ethylbenzene 0.12 95 €b/t.00illdtl
Kylene 0.67 95 €b/10000M
n-Hexane 129,32 95 €0/1000bb1
224 TMP 0.02 95 €h/l000hb€
•
7 of 12 K:\PA\2013\13WE1750.CP3
Separator Venting Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts Aand B-APEN and Permit Requirements
l5ourea is in the Nan-Attainntent.Aron
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Part A,Section ll.D.1.a17
2. Are total facility uncontrolled V0C emissions greater than 5 IPS,NOx greater than 10 TPY or CO emissions greater than 30 TPY(Regulation3,Part B,Section 11.0.317 t
(Not enough information
NON-ATTAINMENT ��e1�
1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than STPY(Regulation 3,Part A,Section 11.0.1.0)? 3 esY%.F�$'',Source Req
2. 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 11,0.217 5. "•1•,,Source Req
!Source requires 0 permit
Colorado Regulation 7,Section XVII
1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,20147 Ye's'',, Sourceissl
(Source is subject to Regulation 7,Section XVII,B.2,G
Section XVII.B.2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G-Emissions Control
Alternative Emissions Control(Optional Section),
a. Is this separator controlled by a back-up ar alternate combustion device(i.e.,not the primary control device)that Is not enclosed? obt The control
(The coconut dmvice iantis aanaratar is not subject to Regolation 7,Section XVi3.6,2.a
Section XVII.e.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Alr Quality Control Commission regulations.This document is
note rule or regulation,and the analysis it contains may not apply lea particular situation based upon the Individual facts and circumstances.This document does not change or substitute for any taw,
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 ado 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 terns of the Clean Air
Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
Colorado Department of Public Health Environment
Air Pollution Control Division
Operation(hrs/yi 8760 The default list of TOC emissions factors are based on Table 2-4"Average Emissions Factors"of the EPA Protocal
SCC Code:31000220:All Equip.Leak Fugitives(Valves,flanges,connections,seals,drains) for Fugitive Equipment Leaks. If the company qualifies to use Table 2-8"Less than 10,000 ppmv"emissions factors
based on provisions of Regulation 7,Section XVII.F,you must update and manually enter the Table 2-8 emissions
Fugitive Component Counts&Emissions
VOC Benzene Toluene Ethylbenzene Xylene n-Hexane
TOC EF TOC EF
• Component lb/hr- kg/hr- Contr Uncontrolle Controlled Uncontrolle Controlled Uncontrolle Controlled Uncontrolle Controlled Uncontrolle Controlled Uncontrolle Controlled
Service Type Count source source of(%) d(tpy) (tpy) d pb/yr) (Ib/yr) d(Ib/yr) (Ib/yr) d(Ib/yr) (Ib/yr) d(lb/yr) (ib/yr) d(Ib/yr) (Ib/yr)
Valves 1810 5.51E-05 2.50E-05 0.0% 0.12 0.1 0.7 0.7 3.5 3.5 0.4 0.4 3.9 3.9 5.9 5.9
Pump Seals 0 7.72E-04 3.50E-04 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Gas Others 0 2.65E-04 1.20E-D4 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Connectors 5428 2.20E-05 1.00E-05 0.0% 0.14 0.1 0.8 0.8 4.2 4.2 0.5 0.5 4.7 4.7 7.1 7.1
Flanges 934 1.26E-05 5.70E-06 0.0% 0.01 0.0 0.1 0.1 0.4 0.4 0.1 0.1 0.5 0.5 0.7 0.7
Open-ended line 1908 3.31E-05 1.50E-05 0.0% 0.08 0.1 0.4 0.4 2.2 2.2 0.3 0.3 2.5 2.5 3.8 3.8
Valves 1620 4.19E-05 1.90E-05 0.0% 0.30 0.3 2.4 2.4 10.5 10.5 1.2 1.2 14.3 14.3 19.9 19.9
. Pump Seals 1 1.12E-03 5.10E-04 0.0% 0.00 0.0 0.0 D.0 0.2 0.2 0.0 0.0 0.2 0.2 0.3 0.3
Light 01 Others 0 2.43E-04 1.10E-04 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Connectors 2884 2.14E-05 9.70E-06 0.0% 0.27 0.3 2.2 2.2 9.6 9.6 1.1 1.1 13.0 13.0 18.0 18.0
Flanges 1050 5.29E-06 2.40E-06 0.0% 0.02 0.0 0.2 0.2 0.9 0.9 0.1 0.1 1.2 1.2 1.6 1.6
Open-ended line 737 3.09E-05 1.40E-05 0.0% 0,10 0.1 0.8 0.8 3.5 3.5 0.4 0.4 4.8 4.8 6.7 6.7
Valves 46 1.85E-05 8.40E-06 0.0% 0.00 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.2 0.2 0.2 0.2
Pump Seals t),. ..... ,1O �w ...maw k � . , , l `.,..... , -, \c\y4i ; I .;'-
Heavy Oil Others 0 _7.05E-05 3.20E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Connectors 289 1.65E-05 7.50E-06 0.0% 0.02 0.0 0.2 0.2 0.7 0.7 0.1 0.1 1.0 1.0 1.4 1.4
Flanges 0 8.60E-07 3.90E-07 0.0% 0.00 0.0 0.0 0.0 0.0 . 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Open-ended line 570 1.59E-05 7.20E-06 0.0% 0.04 0.D 0.3 0.3 ' 1.4 1.4 0.2 0.2 1.9 1.9 2.6 2.6
Valves 13 2.14E-05 9.70E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.1 0.1 0.1
Pump Seals 0 5.29E-05 2.40E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Water/Oil Others 0 1.30E-04 5.90E-05 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
Connectors 40 2.20E-05 1.00E-05 0.0% 0.00 0.0 0.0 0.0 0.1 0.1 0.0 0.0 0.2 0.2 0.3 0.3
Flanges 0 6.39E-06 2.90E-06 0.0% 0.00 0.0 '0.0 0.0 0.0 0.0 0.0 0.0 0.0 ' 0.0 0.0 0.0
Open-ended line 5 7.72E-06 3.50E-06 0.0% 0.00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.D 0.0
TOTALS(tpy) 1.1 1.1 0.00 0.00 0.02 0.02 0.00 0.00 0.02 0.02 0.03 0.03
TOTALS lb/r . 37 37 4 4 4: 4:
•
With safety factor: 1
TOTALS(tpy) 0.00 I D.00 i 0.02 I 0.02 i 0.00 0.00 I 0.02 I 0.02 i 0.03 i 0.03
TOTALS(Ib/yr) -
Emission Factor Source: EPA-453/R-95-017,Table 2x8 -
Stream VOC Fraction(wt) Stream HAP Components(wt fraction)
Gas 0.2766 HAP Gas Light Oil Heavy Oil Water/Oil
Light Oil 1.0000 Benzene 0.0008 0.0041 0.0041 0.0041 The Heavy Oil/Light Oil/Water/Oil stream compositions were determined based on a pressurized
. Heavy Oil • 1.0000 Toluene 0.0040 0.0177 0.0177 0.0177 liquid sample analysis taken 02/12/2019.The gas stream composition,including VOC content,
Water/Oil 1.0000 Ethylbenzen 0.0005 0.0020 0.0020 0.0020 was determined by a sales gas extended analysis taken 2/12/2019.Both sample analyses were
Xylene 0.0045 0.0240 0.0240 0.0240 submitted with the application.
n-Hexane 0.0068 0.0334 0.0334 0.0334
2,2,4-TMP 0.0000 0.0005 0.0005 0.0005 •
Regulator/Considerations
Is this source located in an ozone non-attainment area or attainment maintenance area? Yes
Reg.3 if yes,is this source subject to leak detection and repair(LDAR)requirements per Regulation 7,Section XVII.F or XII.G or 40 CFR,Part 60,Subparts KKK or 00' Yes
If you repond"yes"to the first question and"no"to the second,this source is subject to Regulation 3,Part B,Section III.D.2,Reasonably Available Control Technology(RACT)requirements and must impleme
leak detection and repair program. The engineer should work with the supervisor to craft an LDAR requirement that mirrors the provisions of Regulation 7,Section XVII.F.
Is this source at an onshore"natural gas processing plant"as defined in 40 CFR,Part 60.6 No
Did this source commences construction,reconstruction,or modification after January 20,1984,and on or before August 23, No
If you answer"yes"to both questions above,this source is subject to the provisions of 40 CFR,Part 60,Subpart KKK"Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Pro'
Plants"contained in Regulation 6,Part A.
Reg.6 Dld this source commences construction,reconstruction,or modification after August 23,: Yes
If you answer"yes"to question#1 and#3 this source is subject to the provisions of 40 CFR,Part 60,Subpart 0000"Standards of Performance for Crude Oil and Natural Gas Production,Transmission and
Distribution". Specifically,review subpart 60.5400 for fugitive component leaks and 60.5380 and 60.5385 if the operator reports compressors.
It is possible for en onshore natural gas processing plant to have portions of the facility subject to NSPS KKK and portions subject to NSPS 0000 based on the specific dates of construction of those
- portions of the facility. If this is the case,the operator will need to report each of those respective fugitive component emissions on separate APENs and obtain unique emissions points from the Division.
Is this source located in an ozone non-attainment area or attainment maintenance area? Yes
Reg.7 Is this source at an onshore"natural gas processing plant"as defined in 40 CFR,Part 60.6: No
If you answer"yes"to both questions above,this source is subject to the provisions of Regulation 7,Section XII.G regardless of the date of construction
Is this source at a"natural gas processing plant"as defined in 40 CFR,Part 63.761? No
Reg.8 Is this facility considered a"major source"of HAP as specifically defined in 40 CFR,Part 63.761 for sites that are not prodcution field fe No
If you repond"yes"to both questions above,further review if the provisions of 40 CFR,Part 63.769"Equipment Leak Standards"apply No
Printed 9/27/2019 • Page 9 of 12
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name Crestone Peak Resources Operatin ,LLC
County AIRS ID 123 History File Edit Date 9/26/2019
Plant AIRS ID 962A Ozone Status Non-Attainment
Facility Name Davis 9H-O266
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPS
ID
Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.9 576.4 0.0 4.9 39.3 0.0 0.0 0.0 0.0 0.9 60.7 0.0 4.9 2.6
Previous Permitted Facility total 0.0 0.0 , 0.0 0.0 0.9 576.4 0.0 4.9 39.3_ 0.0 0.0 0.0 0.0 0.9 60.7 0.0 4.9 2.6
001 GP01 Twelve 400 barrel storage tanks 1.1 7757 4.9 40.0 1.1 39.0 4.9 2.0 New SSEF,increased throughput _
002 GP05 2-500 bbl produced water tanks 0.2 133.9 1.1 14.8 0.2 10.0 1.1 0.7 Previously CN b/c beneath thresholds
003 13WE1750 Condensate Loadout 0.2 106.3 0.8 0.2 0.2 5.3 0.8 0.0 Increased throughput?
004 19WE0194 LP Separator Venting 0.3 99.5 1.2 2.1 0.3 5.0 1.2 0.1 Newly requested emission point _
005 19W50195 Fugitives 1.1 0.1 1.1 0.1 Newly requested emission point
006 19WE0196.XP COMP-1(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
007 19WE0197.XP COMP-2(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 - 1.8 0.0 New source,XP due to Horsepower
008 19WE0198.XP COMP-3(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 , 0.9 0.4 1.8 0.0 New source:,XP due to Horsepower
009 19WE0199.XP COMP-4(46-HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
010 19WE0200.XP COMP-5(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 D.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
011 19WE0201.XP COMP-6(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
012 19WE0202.XP COMP-7(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
013 19WE0203.XP COMP-8(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
014 19WE0204.XP COMP-9(46 HP NG RICE) 0.0 0.0 7.3 0.4 8.3 0.0 0.0 0.0 0.9 0.4 1.8 0.0 New source,XP due to Horsepower
FACILITY TOTAL 0.0 0.0 0.0 0.0 67.5 1,119.0 1.1 82.7 57.2 0.0 0.0 0.0 0.0 1.6 62.9 1.1 24.2 0.0 VOC: Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
CO: True Minor(PSD and OP)
HAPS: Syn Minor n-hexane&total
•
Permitted Facility Total 0.0 0.0 0.0 0.0 1.8 1,115.4 1.1 8.0 57.2 0.0 0.0 0.0 0.0 1.8 59.3 1.1 8.0 2.9 Excludes units exempt from permits!APENs
(A)Change in Permitted Emissions 0.0 0.0 0.0 0.0 0.9 -1.4 1.1 3.1 Pubcom required based on requesting syn minor
limits. Mdeling not required based on division
guidance.
Total VOC Facility Emissions(point and fugitive) 60.4 Facility is eligible for GPM.because o 90 tpy
(A)Change in Total Permitted VOC emissions(point and fugitive) -0.3 Project emissions less than 25 tpy
Note 1
Note 2
Page 10 of 12
Printed 9/27/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123
Plant AIRS ID 9B2A
Facility Name Davis 9H-G266
Emissions-uncontrolled (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 0 0 _ 0 0 0 0 0 0 0 0 0 0 0.0
001 GP01 Twelve 400 barrel storage tanks 7134 9734 384 3657 58833 281 40.0
002 GP05 2-500 bbl produced water tanks 7154 22484 14.8
003 13WE1750 Condensate Loadout 390 0.2
004 19WE0194 LP Separator Venting 349 160 3 25 3679 1 2.1
005 19WE0195 Fugitives 8 37 4 48 69 1 0.1
006 19WE0196.XP COMP-1 (46 HP NG RICE) 0.0
007 19WE0197.XP COMP-2(46 HP NG RICE) 0.0
008 19WE0198.XP COMP-3(46 HP NG RICE) 0.0
009 19WE0199.XP COMP-4(46 HP NG RICE) 0.0
010 19WE0200.XP COMP-5(46 HP NG RICE) 0.0
011 19WE0201.XP COMP-6(46 HP NG RICE) 0.0
012 19WE0202.XP COMP-7(46 HP NG RICE) 0.0
013 19WE0203.XP COMP-8(46 HP NG RICE) 0.0
014 19WE0204.XP COMP-9(46 HP NG RICE) 0.0
TOTAL(tpy) 0.0 0.0 0.0 7.5 5.0 0.2 1.9 42.5 0.0 0.1 0.0 0.0 57.2
*Total Reportable=all HAPs where uncontrolled emissions>de minimus values
Red Text: uncontrolled emissions<de minimus
Emissions with controls (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(tpy)
'Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0
001 GP01 Twelve 400 barrel storage tanks 357 487 19 183 2942 14 2.0
002 GP05 2-500 bbl produced water tanks 358 1124 0.7
003 13WE1750 Condensate Loadout 19.5 0.0
004 19WE0194 LP Separator Venting 17 8 0 1 184 0 0.1
005 19WE0195 Fugitives 8 37 4 48 69 1 0.1
006 19WE0196.XP COMP-1 (46 HP NG RICE) 0.0
007 19WE0197.XP COMP-2(46 HP NG RICE) 0.0
11 13WE1750.CP3 9/27/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name Crestone Peak Resources Operating,LLC
County AIRS ID 123
Plant AIRS ID 9B2A
Facility Name Davis 9H-G266
008 19WE0198.XP COMP-3(46 HP NG RICE) 0.0
009 19WE0199.XP COMP-4(46 HP NG RICE) 0.0
010 19WE0200.XP COMP-5(46 HP NG RICE) 0.0
011 19WE0201.XP COMP-6(46 HP NG RICE) 0.0
012 19WE0202.XP COMP-7(46 HP NG RICE) 0.0
013 19WE0203.XP COMP-8(46 HP NG RICE) 0.0
014 19WE0204.XP COMP-9(46 HP NG RICE) 0.0
TOTAL(tpy) 0.0 0.0 0.0 0.4 0.3 0.0 0.1 2.2 0.0 0.0 0.0 0.0 2.9
12 13WE1750.CP3 9/27/2019
CDPHF-. Hydrocarbon Liquid Loading APEN
Form APCD-208
iftAir 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: 13WE1750 AIRS ID Number: 123 / 9B2A/ 003
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Davis 9H-G266
Site Location
Site Location:
SWNE Section 9, T2N, R66W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10188 East 1-25 Frontage Road
Firestone, CO 80504 Contact Person: Taryn Weiner
Phone Number: (303) 774-3908
E-Mail Address2: taryn.weiner@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
n
393 L1 � , In
n
r _ 4
C;J
COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I A� °p"`""`°'"""Htalily 6&tvllOnn�nl
Permit Number: 13WE1750 MRS ID Number: 1 23 / 9B2A/003
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
O Request coverage under construction permit ❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
✓❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
✓❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR
APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS-
Limit Hazardous Air Pollutants (HAPs) with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: truck loadout of condensate from tanks
Company equipment Identification No. (optional): LOAD-1 For existing sources, operation began on: 08/09/2012
For new or reconstructed sources, the projected start-up date is:
Witt this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Is this equipment located at a stationary source that is considered a Major Source of (HAP) ❑ Yes 0 No
emissions?
Does this source load gasoline into transport vehicles? ❑ Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes ❑ No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual 0 Yes ❑ No
average?
Does this source splash fill less than 6750 bbl of condensate per year? ❑ Yes 0 No
Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes 0 No
Av O COLRADO
o 0,7
Form APCD-208 - Hydrocarbon Liquid Loading APEN- Revision 7/2018 2 In,UNa m
Permit Number: 13WE1750 AIRS ID Number: 1 23 / 9B2A/003
[Leave blank unless APCD has already assigned a permit-and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 1,533,000 bbl/year Actual Volume Loaded: 6,923 bbl/year
This product is loaded from tanks at this facility into: tank trucks
(e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Average temperature of 'F
0.6 bulk liquid loading: 52.45
Saturation Factor:
True Vapor Pressure: Psia 60 °F Molecular weight of lb/lb-mot
4.8 displaced vapors: 47. 17
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.
COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 °`p
}{ MTb Ent4ipnmml
Permit Number: 13WE1750 AIRS ID Number: 123 / 9B2A/003
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.154583 /-104.777786
Discharge Height Above i
Ope'ato� Temp Fto*�2ate -� velocity
t Ground Levee rte ¥ T
LOAD-1
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑ Other(describe):
Indicate the stack opening and size: (check one)
O Circular Interior stack diameter (inches):
❑ 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: %
Used for control of: VOCs, HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model:
Combustion
Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: °F Waste Gas Heat Content: Btu/scf
Constant Pilot Light: 0 Yes O No Pilot Burner Rating: MMBtu/hr
Pollutants Controlled:
O Other: Description:
Requested Control Efficiency:
COIORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
Permit Number: 13WE1750 AIRS ID Number. 123 / gB2A/003
[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):
Overall Requested .
Pollutant �'.Description of Control Method(s);, . - Control Efficiency .
(%reduction'In emissions)
PM
SOX
NOX
CO
VOC Enclosed Combustor 95%
HAPs Enclosed Combustor 95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n-Hexane
❑ Condensate 0.2136 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
Crrtena Pollutant-Emissions Inventory
.. �t Requested Annual Peimit�
Emission Factor Actual Annual Emissions
q Emission Lirnrt(s)
Pollutant
Uncontrolled
Source Uncontrolled Controlle L Uncontrolled Controlled
Basis Units ,v�(AP-42 Emissions Emissions Emissions Emissions
M etc �� _ "LE s/"eai , tons/year _
fs ),' ffons/year),' (lions/year) (tin Y ( y_ )
PM
SOX
NO. 0.068 lb/MMBtu AP-42 0.06 0.17
CO 0.31 Ib/MMBtu AP-42 0.27 0.75
VOC 139. lb/bbl AP-42 8.75 00.44 106.34 5.32
- Non-Criteria'Reportable Pollutant Emissions Inventory
Chemical Emission Factor , . Actual Annual Emissions
Chemical Name Abstract Source : Uncontrolled Controlled'
Service CAS Uncontrolled
Units (AP,-42; Emissions Emissionsb
Number Basis M etc..) (pounds/year)
(pounds/year)
mfg.,
Benzene 71432 0.0031 lb/bbl Eng. Est. 390.0 19.5
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543
2,2,4-
Trimethylpentane 540841
Other:
5 Requested values will become permit limitations. Requested limits) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
-- - - COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I : 7L-h�" ,
hT b F. t
Permit Number: 13WE1750 AIRS ID Number: 123 / 9B2A/003
[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.
7,e)/Lity) � - 02/22/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Taryn Weiner Air Quality Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
✓� Draft permit prior to issuance
❑✓ 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 For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303) 692-3175 or (303) 692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303) 692-3150
Denver, CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/aped
COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6 1 u,ro ,
Alpik'ci)Plf--- Gas Venting APEN - Form APED-211
C
4.,,. 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD) website at: www.colorado.aov/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: /5 W E0/q 4 AIRS ID Number: 123 /9B2A I ooti
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 Administrative Information
Company Name': Crestone Peak Resources Operating, LLC .
Site Name: Davis 9H-G266
Site Location: SWNE Section 9, T2N, R66 Site Location
W Weld
County:
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) g 10188 East 1-25 Frontage Road
Firestone, CO 80504 Contact Person: Taryn Weiner
Phone Number: (303) 774-3908
E-Mail Address2: taryn.weiner@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
fi
9 36, 35 R
33
O rzs a
COLORADO
Form APCD-211 - Gas Venting APEN Revision 7/2018 1 I M ==.=,
Permit Number: AIRS ID Number: 123 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other(describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS-
• Limit Hazardous Air Pollutants (HAPs) with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: low pressure separator venting to enclosed
combustor when VRU's are offline
Company equipment Identification No. (optional): Buffer
For existing sources, operation began on: 11/24/2018
For new, modified, or reconstructed sources, the projected start-up date is:
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source
hours/day days/week weeks/year
Operation:
Witt this equipment be operated in any NAAQS ❑✓ Yes ❑ No
nonattainment area?
Is this equipment located at a stationary source that is ❑ Yes ❑✓ No
considered a Major Source of (HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7, 0✓ Yes ❑ No
Section XVII.G?
Ab_ :.COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 2 `,
Permit Number: AIRS ID Number: 123 /9B2A /
[Leave blank unless APCD has already assigned a permit A and AIRS ID]
Section 4 -Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gad/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Btowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes ❑✓ No
Vent Gas BTU/SCF
Gas Venting Heating Value:
Process Parameters5:
Requested: MMSCF/year Actual: MMSCF/year
-OR-
Liquid Throughput 28 36
Requested: , �-t bbl/year Actual: __ bbl/year
Process Parameters5:
Molecular Weight: 34.14
VOC (Weight%) 60.15
Benzene (Weight%) 0.11
Vented Gas Toluene (Weight%) 0.05
Properties: Ethylbenzene (Weight%) 0.001
Xylene (Weight%) 0.01
n-Hexane (Weight%) 1.11
2,2,4-Trimethylpentane (Weight%) 0.0002
Additional Required Information:
✓❑ Attach a representative gas analysis (including BTEX Et n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis (including BTEX Et n-Hexane, temperature, and
pressure)
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
A .co 1O RDO
Form APCD-211 Gas Venting APEN - Revision 7/2018 3 I `s 'ro A
Permit Number: AIRS ID Number: 123 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.154583 /-104.777786
Operator ,� , c Above Ground Le�el� Temp Flov Rate"� Velocityq
Stack ID No. ( FI Alf) fft/sec)
Sep. Vent 20.0
Indicate the direction of the stack outlet: (check one)
❑✓ Upward ❑Downward ❑ Upward with obstructing raincap
❑Horizontal ❑Other (describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches): 48
❑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.
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Pollutants Controlled: VOCs, HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model:
Combustion
❑✓ Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
:COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 4
Permit Number: AIRS ID Number: 123 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 7 - Emissions Inventory Information
Attach alt 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):
Overall;Requested
Pollutant Description of Control Methods) Control Efficiency
reduction missio
PM
SOX
NOx
CO
VOC Enclosed Combustor 95%
HAPs Enclosed Combustor 95%
Other:
From what year is the following reported actual annual emissions data? N/A
Cntena:Pollutant Emissions Inventory
Emission Factorf d Requested Annual Permit
Actual Annual Emissions
Emission Limit(s)5
Pollutant
Source Uncontrolled Controlled; Uncontrolled Controlled
Uncontrolled Units .('A , Emissions ` Emissions Emissions Emissions'
Basis fg, tons/ ea'r tons/ar
u�r
PM
SOx
NO„ 0.068 Ib/MMBtu AP-42 -- -- -- --9--24 CJ:
CO 0.31 Ib/MMBtu AP-42 -- — -- -471-0 1,2c)
:;) VOC --5472— lb/Msef_ Eng. Est. — -- 99.50 4.97
Non Cntena Reportable Pollutant Emissions Inventory
Chemical�E Emission Factor Actual Annual Emissions
Chemical Name
Se Abstract [ rolled
Service (CA's) Uncontrolled Source Uncontrolled Cont
( ) Units_ (AP-42, Emissions Emissions6
Number Basis Mfg•>etc.) (pounds/year) (Pounds/year)
Benzene 71432 -0-09 el: Ib/ldiscf- Eng. Est. 349 17
'fliR
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543 1-0'0�.1 2.:t-,...1 Eng. Est. 3,679 184
2,2,4- It l tirYt
Trimethylpentane 540841
Other:
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 5 �
Permit Number: AIRS ID Number: 123 /9B2A/
[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.
71(/(.471,-) 02/22/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Taryn Weiner Air Quality Engineer
Name (please print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303) 692-3175 or (303) 692-3148
APCD-SS-B1
4300 Cherry Creek Drive South APCD Main Phone Number
Denver, CO 80246-1530 (303) 692-3150
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 7/2018 6 I � F Y, m.IM
DP Fugitive Component Leak Emissions APEN
-MN tit Form APCD-203
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. 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 fugitive component leak emissions only. If your emission source does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD)website at: www.colorado.gov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19 we /q5 AIRS ID Number: 123 /9B2A/ 005-
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Name': Crestone Peak Resources Operating, LLC
Site Name: Davis 9H-G266
SWNE Section 9 T2N R66W Site Location Weld
Site Location: , , County:
NAICS or SIC Code: 1311
Mailing
it ing AdInclude idress: 10188 East 1-25 Frontage Road
p Code)
Firestone, CO 80504 Contact Person: Taryn Weiner
Phone Number: (303) 774-3908
E-Mail Address2: taryn.weiner@crestonepr.com
1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork. 06 ,
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail tOhe address provided.wy COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 1 I LiD.NY `°`"Y""¢""`°"""
Permit Number: AIRS ID Number: 1 23 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly-reported emission source (check one below)
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change process or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
Company equipment Identification No. (optional): FUG
For existing sources, operation began on: $/09/2012
For new or reconstructed sources, the projected start-up date is:
❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source hours/day days/week weeks/year
Operation:
Facility Type:
❑✓ Well Production Facility5
❑Natural Gas Compressor Stations
❑Natural Gas Processing Plants
❑ Other(describe):
5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII.
COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN- Revision 7/2018 2 I �¢ VO. „
Permit Number: AIRS ID Number: 1 23 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Regulatory Information
What is the date that the equipment commenced construction? 2012
Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes ❑No
Will this equipment be located at a stationary source that is considered a ❑Yes ❑✓ No
Major Source of Hazardous Air Pollutant (HAP) emissions?
Are there wet seal centrifugal compressors or reciprocating compressors111 Yes ❑ No
located at this facility?
Is this equipment subject to 40 CFR Part 60, Subpart KKK? ❑Yes ✓❑No
Is this equipment subject to 40 CFR Part 60, Subpart OOOO? ❑Yes No
Is this equipment subject to 40 CFR Part 60, Subpart OOOOa? ❑✓ Yes ❑No
Is this equipment subject to 40 CFR Part 63, Subpart HH? ❑Yes ❑✓ No
Is this equipment subject to Colorado Regulation No. 7, Section XII.G? ❑Yes ✓❑No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.F? E Yes ❑No
Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? ❑✓ Yes ❑No
Section 5 - Stream Constituents
❑✓ The required representative gas and liquid extended analysis (including BTEX) to support the data below has
been attached to this APEN form.
Use the following table to report the VOC and HAP weight%content of each applicable stream.
VOC 2,4 Benzene' Toluene Ethylbenzene Xylene n-Hexane,, 2,
Steam Trtmethylpetitane '
(wt%) (wt%)
n
Gas 27.66 0.08 0.40 0.05 0.45 0.68 0.0006
Heavy Oil
(or Heavy Liquid) 100 0.41 1 .77 0.20 2.40 3.34 0.05
Light Oil
(or Light Liquid) 100 0.41 1 .77 0.20 2.40 3.34 0.05
Water/Oil 100 0.41 1 .77 0.20 2.40 3.34 0.05
Section 6 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.1 54583 / -104.777786
Attach a topographic site map showing location
COLORADO
Form APCD-203 -'Fugitive Component Leak Emissions APEN - Revision 7/2018 .3 I �� °" °°°`°"
Permit Number: AIRS ID Number: 1 23 /9B2A/
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 7 - Leak Detection and Repair (LDAR) and Control Information
Check the appropriate boxes to identify the LDAR program conducted at this site:
❑ LDAR per 40 CFR Part 60, Subpart KKK
❑Monthly Monitoring- Control: 88% gas valve, 76% light liquid valve, 68% tight liquid pump
❑Quarterly Monitoring- Control: 70%gas valve, 61% light liquid valve, 45% tight liquid pump
❑✓ LDAR per 40 CFR Part 60, Subpart OOOO/OOOOa
❑Monthly Monitoring- Control: 96%gas valve, 95% light liquid valve, 88% light liquid pump, 81%
connectors
❑✓ LDAR per Colorado Regulation No. 7, Section XVII.F
❑Other6:
❑No LDAR Program
6 Attach other supplemental plan to APEN form if needed.
COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 4 I Av '„ ` °pRT.�
Permit Number: AIRS ID Number: 1 23 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8 - Emission Factor Information
Select which emission factors were used to estimate emissions below. If none apply, use the table below to
identify the emission factors used to estimate emissions. Include the units related to the emission factor.
❑Table 2-4 was used to estimate emissions7.
❑✓ Table 2-8 (< 10,000ppmv) was used to estimate emissions7.
Use the following table to report the component count used to calculate emissions. The component counts listed
in the following table are representative of:
❑✓ Estimated Component Count
❑Actual Component Count conducted on the following date:
Equipment Type
Service Open Ended
Connectors Flanges Pump Seals Valves ; Other9
:Lanes _
Count8 5,428 934 1,908 0 1,810 0
Emission Factor 2,20E-05 1.26E-05 3.31 E-05 7.72E-04 5.51 E-05 2.65E-04
- units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source
Heavy Oil (or Heavy Liquid)
Count8 289 0 570 -- 46 0
Emission Factor 1.65E-05 8.60E-07 1.59E-05 -- 1.85E-05 7.05E-05
units lb/hr/source lb/hr/source lb/hr/source -- lb/hr/source lb/hr/source
Light Oil (or Light Liquid)
Count$ 2,884 1,050 737 1 1,620 0
Emission Factor 2.14E-05 5.29E-06 3.09E-05 1.12E-03 4.19E-05 2.43E-04
Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source
Water/Oil
Count8 40 0 5 0 13 0
Emission Factor 2.20E-05 6.39E-06 7.72E-06 5.29E-05 2.14E-05 1.30E-04
Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source
7 Table 2-4 and Table 2-8 are found in U.S. EPA's 1995 Protocol for Equipment Leak Emission Estimates (Document EPA-453/R-
95-017).
8 The count shall be the actual or estimated number of components in each type of service that is used to calculate the"Actual.
Calendar Year Emissions"below.
9 The"Other"equipment type should be applied for any equipment other than connectors, flanges, open-ended lines, pump
seals, or valves.
COLORADO .
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 5 Lac :=1.7;,,".Z.:,,
Permit Number: AIRS ID Number: 1 23 /9B2A/
[Leave blank unless APCD has air eadv assigned a permit#and AIRS ID]
Section 9 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
From what year is the following reported actual annual emissions data? 201 8
Use the following table to report the criteria pollutant emissions and non-criteria pollutant (HAP) emissions from source:
(Use the data reported in Section 8 to calculate these emissions.)
.'Actual Annual Emissions Requested Annual Permit Emission
Chemical Name CAS - Limit(s)11
Number Uncontrolled Controlled10 Uncontrolled Controlled
(tons/year), (tons/year) (tons/year) e(tons/year):
VOC -- 0.37 0.37 1.12 1.12
Does the emissions source have any actual emissions of non-criteria pollutantsLi Yes No
(e.g. HAP- hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant (HAP) emissions from source:
Requested Annual Permit Emission
Chemical Name
CAS Actual Annual Emissions Lim-t(s)1�
Number Uncontrolled Controlled10 Uncontrolled- Controlled
Ps/year) -(lbs/year) (lbs/year) (lbs
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xytene 1330207
n-Hexane 110543
2,2,4 540841
Trimethylpentane
Other:
10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
11 Requested values will become permit limitations. Requested limit(s)should consider future process growth,component count
variability, and gas composition variability.
COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 6 I x �n a sn.:ranmm,
Permit Number: AIRS ID Number: 1 23 /9B2A/
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct.
76.447y1 � � 02/22/2019
Signature of Legally Authorized Person (not a vendor or consultant) Date
Taryn Weiner Air Quality Engineer
Name (print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
I✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation,No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303) 692-3175 or (303) 692-3148
APCD-SS-B1
4300 Cherry Creek Drive South APCD Main Phone Number
Denver, CO 80246-1530 (303) 692-3150
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd
a :COLORADO
Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 7/2018 7 I' pQ .Dcp.,rtun:ar PuWc
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