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HomeMy WebLinkAbout20194616.tiffCOLORADO Department of Public Health b• Environment Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 October 16, 2019 Dear Sir or Madam: RECEIVED 0CT 2 3 2019 WELD COUNTY COMMISSIONERS On October 17, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating LLC - Gurtler 24HZ. 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 & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pvbt;c 2W I o /ag/!°I PL(TP) HL(LV)s P.04/ER./CHICK), O 14) IQ/2.4/iq 2019-4616 C.° Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating LLC - Gurtler 24HZ - Weld County Notice Period Begins: October 17, 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: Gurtler 24HZ EFtP Well Pad Site NWNW SEC 30 T2N R64W Weld County The proposed project or activity is as follows: The applicant proposes to permit a new oil and gas production facility located within the eight -hour (8 -hr) Ozone Control Area of Weld County. Emission points with this facility include condensate tanks, produced water tanks, condensate loadout, fugitive emissions, and separator gas flaring. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0832 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Christopher Kester Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Zia COLORADO Department of Public Health b Environment Denver, Colorado 80246-1530 COLORADO Department of Public Health @ Envirct rent COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE0832 Issuance: 1 Date issued: Issued to: Crestone Peak Resources Operating, LLC Facility Name: Gurtler 24HZ Plant AIRS ID: 123/A082 Physical Location: NWNW SEC 30 T2N R64W County: Weld County Description: Well. Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TANKS 001 ' Eight (8) 500 bbl fixed roof condensate storage tanks Enclosed combustor PW 002 Two, (2) 500 bbl fixed roof condensate storage tanks Enclosed combustor LOAD -1 003 Truck loading from condensate tanks by submerged fill Enclosed combustor Buffer 004 Low pressure separator venting to combustor when VRU's are offline Enclosed combustor FUG 005 Fugitive Component Leak Emissions None This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup Page 1 of 15 te,t- 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 form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Point 004: Upon commencement of operation, the operator must install a flow meter to monitor and record volumetric flow rate of natural gas vented from each separator covered by this permit. 5. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 6. The operator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 7. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Page 2 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 N0X V0C CO TANKS 001 --- 2.3 74.6 10.3 Point PW 002 --- --- 8.0 --- Point LOAD -1 003 --- --- 5.5 --- Point Buffer 004 --- --- 5.0 --- Point FUG 005 --- --- 1.8 --- Fugitive Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 8. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 9. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Reference: Regulation 3, Part C. II.E.) Total emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 100 tons per year of VOC 10. 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.) Page 3 of 15 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 Facility Equipment ID AIRS Point Control Device Pollutants Controlled TANKS 001 Enclosed combustor VOC and HAP PW 002 Enclosed combustor VOC and HAP LOAD -1 003 Enclosed combustor VOC and HAP Buffer 004 Enclosed combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 11. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TANKS 001 Condensate throughput 1,825,000 barrels 1,216,667 barrels 1,825,000 barrels PW 002 Produced water throughput LOAD -1'. 003 Condensate loaded Buffer 004 Natural gas routed to control device 2.93 MMscf The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 12. Point 003: Condensate loading to truck tanks must be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E) 13. Point 004: Upon commencement of operation, the owner or operator must continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator must use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 14. Points 001, 002, and 004: The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) Page 4 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 15. Point 003: 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.) 16. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 17. Point 003: This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a combustor. (Reference: Regulation 3, Part B, III.D.2) 18. Point 003: 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. 19. Point 003: 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): 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 tog available to the Division on request. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 20. Point 003: 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. Page 5 of 15 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 21. Point 001: This source is subject to Regulation Number 7, Section XII. The operator must comply with all applicable requirements of Section XII and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Section XII.C.) (State only enforceable) 22. Point 005: This source is subject to Regulation No. 7, Section XII.C General Provisions (State only enforceable). All condensate collection, storage, processing and handling operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. The operator shall comply with all applicable requirements of Section XII. 23. Points 001, 002 £t 004: The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 24. Points 001 Et 002: The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. Page 6 of 15 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 25. Points 001 £t 002: The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. 26. Point 005: Fugitive component leaks at this well production facility are subject to the Leak Detection and Repair (LDAR) program requirements, including but not limited to: monitoring, repair, re -monitoring, recordkeeping and reporting contained in Regulation 7, Section XVII.F. In addition, the operator shall comply with the General Provisions contained in Regulation 7, Section XVII.B.1. 27. Point 004: The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation 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 & MAINTENANCE REQUIREMENTS 28. Points 001, 002, 003 £t 004: Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 0£tM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 29. Point 001 Ft` 003: The owner or operator must complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis must be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 30. Point 004: The owner/operator must complete an initial site specific extended gas analysis ("Analysis") within one hundred and eighty days (180) after commencement of operation or issuance of this permit, whichever comes later, of the natural gas vented from this emissions unit in order to verify the VOC, benzene, toluene, ethylbenzene, xylenes, n -hexane, and 2,2,4- trimethylpentane content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be submitted to the Division as part of the self -certification and must demonstrate the emissions factors established through the Analysis are less than or equal to, the emissions factors submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and Page 7 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 31. Point 005: Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, the owner or operator shall complete the initial extended gas analysis of gas samples that is representative of volatile organic compound (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. The operator shall submit the results of the gas analysis and emission calculations to the Division as part of the self -certification process to ensure compliance with emissions limits. 32. Point 005: Within one hundred and eighty 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 33. Point 001: On an annual basis, the owner or operator must complete a site specific analysis ('Analysis"), including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis is greater than or equal to the emissions factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 34. Point 004: On an annual basis, the owner/operator must complete a site specific extended gas analysis ("Analysis") of the natural gas vented from this emissions unit in order to verify the VOC content (weight fraction) of this emission stream. Results of the Analysis must be used to calculate site -specific emission factors for the pollutants referenced in this permit (in units of lb/MMSCF gas vented) using Division approved methods. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis are less than or equal to, the emission factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factor submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address this/these inaccuracy(ies). Page 8 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 35. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 36. 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. 37. 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 9 of 15 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 38. 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. 39. 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. 40. 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. 41. 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. 42. 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 257-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christopher Kester Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating LLC Page 10 of 15 COLORADO Air Pollution Control Division Department of 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 alt 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. Page 11 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 10,567 528 Toluene 108883 12,326 616 Ethylbenzene 100414 596 30 Xylenes 1330207 4,604 230 n -Hexane 110543 30,720 1,536 2,2,4-Trimethylpentane 540841 425 21 002 Benzene 71432 8,517 426 n -Hexane 110543 26,767 1,338 003 Benzene! 71432 845 42 Toluene 108883 985 49 Xylenes 1330207 368 18 n -Hexane 110543 2,455 123 004 Benzene 71432 609 30 Toluene' 108883 706 35 Xylenes ' 1330207 370 18 n -Hexane 110543 5,559 278 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year ( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.06801b/MMBtu 0.06801b/MMBtu AP -42 CO 0.31001b/MMBtu 0.31001b/MMBtu AP -42 VOC 1.635 0.08175 Representative non -site -specific pressurized sample and Promax 71432 Benzene 0.00579 0.000290 108883 Toluene 0.00675 0.000338 100414 Ethylbenzene 0.00033 0.000016 1330207 Xylene 0.00252 0.000126 110543 n -Hexane 0.01680 0.000840 540841 2 2 4- Trimethylpentane 0.00023 0.000012 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 12 of 15 Point 002: COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.262 0.0131 CDPHE Emission Factors 71432 Benzene 0.007 0.00035 110543 n -Hexane 0.022 0.0011 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Point 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source VOC 0.119810 0.005991 71432 Benzene 0.000463 0.000023 AP -42 Chapter 5.2, Equation 1 108883 Toluene 0.000540 0.000027 1330207 Xylene 0.000202 0.00001.0 110543 n -Hexane 0.001350 0.000068 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) = 4.0 psia M (vapor molecular weight) = 54.1 lb/lb-mot T (temperature of liquid loaded) = 520 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Point 004: CAS # Pollutant Uncontrolled Emission Factors (lb/MMscf) Controlled Emission Factors (lb/MMscf) Source VOC 68343 3417 Representative non -site -specific gas sample 71432 Benzene 208.1 10.4 108883 Toluene 241.1 12.1 1330207 Xylene 126.4 6.3 110543 n -Hexane 1899.5 95.0 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 13 of 15 Point 005: COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Component Gas Service Heavy Oil Light Oil Water/Oil e Service Service Connectors 8467 451 4499 62 Flanges 1458 0 1639 0 Open-ended Lines 2976 890 1150 8 Pump Seals 0 0 2 0 Valves 2824 72 2527 20 Other* 0 0 0 0 VOC Content (wt. fraction) 0.2767 1 1 1 Benzene Content (wt. fraction) 0.0008 0.0028 0.0028 0.0028 Toluene Content (wt. fraction) 0.0012 0.0101 0.0101 0.0101 Ethylbenzene (wt. fraction) 0.0001 0.0014 0.0014 0.0014 Xylenes Content (wt. fraction) 0.0011 0.0136 0.0136 0.0136 n -hexane Content (wt. fraction) 0.0059 0.0288 0.0288 0.0288 *Other equipment type includes compressors, pressure relief valves, relief valves, diaphragms, drains, dump arms, hatches, instrument meters, polishrods andvents TOC Emission Factors (kg/hr-component): Component ' Gas Service . Heavy Oil Light Oil Water/Oil Service Connectors 1.00E-05 7.50E-06 9.70E-06 1.00E-05 Flanges 5.70E-06 3.90E-07 2.40E-06 2.90E-06 Open-ended Lines 1.50E-05 7.20E-06 1.40E-05 3.50E-06 Pump Seals 3.50E-04 NA 5.10E-04 2.40E-05 Valves 2.50E-05 8.40E-06 1.90E-05 9.70E-06 Other 1.20E-04 3.20E-05 1.10E-04 5.90E-05 Source: EPA -453/R95-017 Table 2-8 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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 Page 14 of 15 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) Point 001: This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2, 2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register website at: https://www.federalreQister.Rov/documents/2016/06/03/2016- 11971 /oil -and -natural -gas -sector -emission -standards -for -new -reconstructed -and -modified -sources 9) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: HOC It HAP PSD True Source of: CO NANSR Synthetic Minor Source of: VOC, NOx 10) 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. goy/ 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 15 of 15 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Christopher tester 414619: 8/23/2019 9/24/2019 Section 01 - Facility Information Company Name: Crestone Peak Resour County AIRS ID: 123 Plant AIRS ID: A082 Facility Name: Physical Address/Location: NWNW quadrant of Section 30, Township 2N, Range 64W County: Type of Facility: Exploration & Production Well Pad What industry segment? OIl 0, Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ carbon Monoxide (CO) Curtler,i24H2�, _ Operating LLC Weld County Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) Quadrant Section Township Range NWNW.... 30 N 64 Ozone (NOo & VOC) AIRs Point# Emissions Source Type Equipment Name Emissions Control? Permit# Issuance# Self Cert Required? Action Engineering Remarks 001 - Condensate Tank .,TANKS Yes .19 0083 2. Yes _ Pet 2[t[nitSa� fss�ano" 002 ProducedWaterTank 's PW Yes ' 19WE0832 " 1 Yes . 003 Liquid Loading ' LOAD -1 yes- 19W€0832 1 Yes 004 Separator Venting Buffer Yes 19WE0832 1 ye9 005 - Fugitive Component Leeks FUG No 19W00632 I Yes Section 03 - Description of Project New proposed synthetic minor facility svi Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? ,,Requesting Synthetic^Mlrlo -up date of 12/31/2019 Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No _ Yes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants herr SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP ❑ ❑J HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory 001 Condensate Tank Facility AIRS ID: County Plant 002 Paint Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions -Storage Tank(s) Actual Condensate Throughput = Requested Permit Unlit Throughput= '2825,000 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = Requested Monthly Throughput = 155000 Barrels (bbl) per month f Barrels (bbl) per year Potential to Emit (PTE) Condensate Throughput Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per BBL of liquid produced = 12102 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 4 Btu/scf 0 MMBTU per year 60,555 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 66,555 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (Ib/hbl) Oh/bbl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source VOC 0.011750 0.000290 Benzene Toluene 9i Ethylbenzene .y5,noD7 <v.: Xylene 0,000126 02100140 0.000012 n -Hexane 224 TMP i0 0.400233 Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 PM2.5 0.0003 4.0003 0.0025 9.0110 NOx CO Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 1491.9 9.0 0.0 5451.9 74.6 12671 0.2 0,0 0.0 0.2 0.2 42 0,2 0,0 O21 0.2 0,2 42 2.3. 9.0 0.0 2.3 2,3 384 10.? 0.0 0.0 10.3 10,3 17S2 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 101167 0 0 10067 528 12319 0 0 .9.2319 616 597 0 0 597 30 4599 0 0 4594 290 30600 0 ₹l 30600 25:33 425 5 0 . 425 21 Section 06- ulatory Summary Analysis Regulation 3, Parts A, 0 Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is sub(ect to Regulation 7, Section XII,C•F Regulation 7, Section XII.G, C Storage Tank is . not stabled to Regulation 7, Section XII<G Regulation 7, Section XVII.B, C.1;IC.3 Storage tank is subject to Regulation 7, Section XV1€, B, C,1 & C,3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XV€€C.2 Regulation 6, Part A, NIPS Subpart Kb Storage Tank is tnt suhjest to 531'S Xb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MALT HH (See regulatory applicability worksheet for detailed analysis) 3 0116 K:\PA\2019\19 W E0832. CP1 Condensate Storage Tank(s) Emissions Inventory Section 09 - Inventory SCC Coding and Emissions Factors Section 07- Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions faders based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? 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 OS - Technical Analysis Notes ;toprpserttfSiyq.n fiip, AIRS Point R 001 Process # 01 SCC Code Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.01 0 lb/1,000 gallons condensate throughput PM2.5 0.01 0 lb/1,000 gallons condensate throughput NOx 0.06 0 lb/1,000 gallons condensate throughput VOC 38.9 95 lb/1,000 gallons condensate throughput CO 0.27 0 lb/1,000 gallons condensate throughput Benzene 0.14 95 lb/1,000 gallons condensate throughput Toluene 0.16 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput Xylene 0.06 95 lb/1,000 gallons condensate throughput n -Hexane 0,40 95 lb/1,000 gallons condensate throughput 224 TMP 0.01 95 lb/1,000 gallons condensate throughput 4 of 16 K:\PA\2019\19WE0832.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Perk Requirements 'Soma: is in ^lee Nan-. AttuiomaetArea ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1.a)? 2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Menlo05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greaterthan 5TPY, NOx greaterthan to TPY or CO emissions greaterthan to TPY (Regulation 3, Part B, Section 11.0.3)? 'You Ftaos iodinated tint source Is in the Nan -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissionsfrom any criteria pollutants from this individual source greater than l TPY (flegulad0n 3, Part A, Section Il.D.1a)? 2. Is the construction date (service date) priarto 12/30/2002: and not modified after 32/31/2002 (See PS Merto'o5-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are totalfacility uncontrolled VOL emissions greater than 2TPY, 000 greaterthan S TP7 or CO emissions greater than 10 TP? (Regulation 3, Part B, Section 11.0.2)? JSat. permiS Colorado Regulation 7, Section alt.C-F 1. is thisstorage tank located in they -hr ozone control area or any ozonenon-attainment area oranainment/malntenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. kthh storage tan k located upstream of a natural gasprocessing plant? 'Storage took is a=rb;ectto Regulator 7, Rxh'oa 0I1x.F 5eaton 101.0.1 —General Requirements forAir Pollution Control Equipment —Prevention of Leakage Section Xll.C.2—Emission Estimation Procedures Section 011.0— Emissions Control Requirements Section XILE —Monitoring Section XII.F— Recordkeeping and Reporting Colorado Regulation 7, Section X11.0 1. Is this storage tank loafed in the 3 -hr ozone control area or any ozone non -attainment area or attalnment/maintenance area? 2. Is this stoagetank located rata natural gas processing plant? 3. Doa thisoorage tank exhibit "Flash" (e.g. storing non-stabilbed liquids( emissions and have uncontrolled actual emissions greater than or aquaita 2 tans per year VOC? Storage rank is not subiect to ltegid00on 7, 5ec;ior, X11.0 Section XII.G.2 -Emissions Control Requirements Section oll.C.1—General Requirements for Air Pollution Control Equipment —Prevention of Leakage Seaton xll.C.2—Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. k this condensate storage tank' located at an oil and gas exploration and production operation, well production facility`, natural gas compressor station' ornatural gas processing plant? 3. Is this condensatestorage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions" ofthis storage tank equal to or greater than 6 tons per year VOC? Stof milli O s:1 000. Roottottion Y, 5euSan MI, 0, G S' C.3 Section croon— Central Provisions for Air Pollution Control Equipment and Prevention of EmLssions Section 0VII.0,0 - Emissions Control and Monitoring Pravblons Section XVII.C.3-,Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? ISVoroge lark is 1015715 to Itegu:atlon 7, 00150n 0511.01 Section X011.0.2 - Capture and Mongodngtor Storage Tame: fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance foroolatlle Organic 00012 Storage Vessels 1. is the individual storage vessel capacity greater than or equal to 75 cubic meters( m") (-422 BBIs]? 2. Does the storage vessel meet the following exemption in 6o.111h(d)(4)? a. Daes the vessel has a design capacity leas than or equal to 1,589.874 ma ("10,000 BBL] used for petroleum' or condensate stored, processed, ortreated prior to custody transfer' as defined in 60.1116? .13. Was this condensate stoagetank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) afterluly 23, 1904? 4. Does the tank meet the definition of "storage vessel"' In 00.111b? 5. Do.thestoage vessel store a"volatile organic liquid (VOL)"sas defined in 00.1111? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess 01204.9 kPa ("29.7 psi] and without emissions to the atmosphere (60.110b(d)(2)l?i or b. The design capacity Is greaterthan &equal to 151 me [-95o BBL] and stores a liquid with a maximum true vapor pressure° less than 35 kPa (6o.110b(h)]?i or c. The design capacity is greaterthan or equal to 75 Ma. ("472 BBL] but less than 151 ma [`950 BBL] and stores a liquid with a maximum true vaporpressurea less than 150 kPa(60.130b(b))? 'Storage Tank is oat' suhieS to turfs till Subpart A, General Provisions 000112k- Emissions Control Standards for VOL 5601136 -Testing and Procedures §60.1156- Reporting and Recordkeeping Requirements §6a116b- Monitadngo&Operations . 40 CFR. Pert 60, Subpart 0000, Standards of Performance far Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment car natural gas transmission and storage segment of the industry? 2. Was fhb condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) heCeeen August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greaterthan or equal to 6 tons per year? 4. DoesthS condensate storage vessel meetthe definition of "storagevessel' per 505430? 5. Is the storage vaselsubjertto and controlled in accordance with re uirements for store evessels "in 40 CFR Part 60 Subpart 0b or 40 CFR Part 63 Sub art HH? 'Storage Tank is not sublactto PiSPs 0000 Subpart A, General Provisions per §60.5425 Table 3 4605395 - Emissions Control Standards for VOC 4605413-Tening and Procedures 460.5390(g) - Notification, Reporting and Recordkeeping Requirements 000.0416(a(- Cover and Closed Vent System Monitoring Requirements §60.5417- Control Device Monitoring Requirements (Note: Ifs storage vessel is previously determined is be subject. Moo mama due to emissions above 6 tons per year vac on the applicability determination date, it should remalnsubject to N0Ps mace per 6o.s36s(e)(2] even if potential VOC emissions drop below 6 tons per year( 40 CFR. Part 63, Subpart MAR RH, Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. Afacility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. Afadllry that processes, upgrades or acres natural gas prior to the point at which natural gas enters the natural gas transmission and storage sour. category or is delivered to a final end users (63.76o(a)(3))? 2. Is the tank located at a facility that is major` for HAPs? - 3. Does the tank meet the definition of"storage vessel"' in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential -for flash emissions' per 63.761? . 5. Is the tank subjectto control requirements under 40 CFR Part 60, subpart Kb or subpart 0000? . IStoaga-funk Is notsdb)ectta MAC, HH Subpart A, General provisions per §63.764 (a)Table §63.766- Emissions Control Standards 563.79- Monitoring Recordkeeping §63.775 -Reporting RACP Review RACT review Is required if Regulation 7 does not apply AND If the tank is In the non -attainment area. Ifthetank meets both criteria, then review RACE requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis if contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any lam, 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 orregulalion will control. The use of non -mandatory language such as "recommend" "may," 'should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must and "required are intended to describe controlling requirements under the teens of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes Re aAM Yes Yien Yaw& Source Req Ga to next Source Req Continue-' Continue-' source is.. Continue Storage Tar ontinue Go to then Go to then Source is st [5adlikkOjSource isst Storage Tar fagag MEM Continue-' Storage Tar Iles 'Continue-' arnoR Storage Tar Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: County 0052' Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput= Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating= -1;x16;667:' Barrels (bbl) per year Requested Monthly Throughput = 103333 Barrels (bbl) per month Potential to Emit (PTE) Produced Water Throughput = Secondary Emissions - Combustion Device(s). Heat content of waste gas= a� 534. Btu/scf Volume of waste gas emitted per BBL of liquid produced = > 4 4 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year 0 MMBTU. per year ' 8,859 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 8,859 MMBTU per year Section 04 - Emissions Factors & Methodologies U Will this storage tank emit flash emissions? Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) Emission Factor Source VOC 0.262 0.007....._.'_ 0.01310 0.000.35 0.00000 000000 0,00000 0.00110 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 0.000 Control Device Emission Factor Source Pollutant Uncontrolled Uncontrolled (lb/bbl) (Produced (waste heat Water combusted) Throughput) PM10 PM2.5 NOx CO (Ib/MMBtu) t Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ibs/month) VOC PM10 PM2.5 NOx CO 159.4 0.0 0.0 109:4 8.0 1354 0.0 0.5 0.e 0.0 0.0 6 0.0. 0.0 03 0.0 0.0 6 0.3 0.0 5.0 0.3 0.3 51 1.4 4.0 541 3.4 1.4 233 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 0517 0 €7 0517 426 0 0 0 0 0 0 0 :0 0 0 0 0 0 0 0 26767 0 0 26767 1335 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Salome requires a permit Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7,:Sectian XVIl, B. C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is sub(ect to Regolatiou 7, Section XVll.C.2 Regulation 6, Part A, NIPS Subpart 0000 Storage Tank is not subject to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 6 of 16 K:\PA\2019\19 W EOB32.CP1 Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions,are the emissions factors based on a pressurized liquid water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. - .. If no, the permit will contain an"Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 far additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point p 002 Process P 5CC:Code 01 4-.04-003-16 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons liquid throughput PM2.5 0.00 0 lb/1,000 gallons liquid throughput NOx 0.01 0 lb/1,000 gallons liquid throughput VOC 6.2 95 lb/1,000 gallons liquid throughput CO 0.05 0 lb/1,000 gallons liquid throughput Benzene 0.17 95 lb/1,000gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 0.52 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput. 7 of 16 - K:\PA\2019\19WE0832.CP1 Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Re ,ulation 3 Parts A and B- APEN and Permit Requirements ..'Source is el the ':den.Attainmene Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.e)? 2. Is the operator claiming less than 1% crude oil and is the tank located ate non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5TPY, Nog greater than 10 TPY or CO emissions greater Phan 10 TPY (Regulation 3, Part B, Section 11.0.3)? You have indicated thee soarce is in the Nan :Attalom®nt Arca NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than TPY (Regulation 3, Part A, Section ll.0.1.al? 2. Is the operator claiming less than 1% crude oil and is the tank located et a non-commercial facility for processing ail and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10TPY (Regulation 3, Part 0, Section 11.0.2)? Isaur-.e requires a pennit Colorado Regulation 7, Section XVII 1. Is this tank located ate transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4, Are uncontrolled actual emissions" of the storage tank equal to or greater than 6 tons per year VOC? 'Storage teak In subject to Regalatien 7, Section XVii, B, C.1 k, C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3- Recardkeeping Requirements 5. Does the produced water storage tank contain only "stabilized"liquids? If no, the following additional provisions apply. as Yes (Storage Yank €e :Athlete to Regulation 7. Section XV Ii.C.2 Section XVIl.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 5e. Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water storage vessel located at a facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR,60.2) between August 23, 2011 and September 10, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430? 'Storage Tank is not aubleat to Reps 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements 160.5417 - Control Device Monitoring Requirements ' [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tans per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) euen R potential VOC emissions drop below 6 tons per year] RACT Review RACT review is required If Regulation 7 does not apply AND lithe tank Is In the non -attainment area. If the tank meets both criteria, then review RACE requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is note 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 ofany conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,""may,' 'should,' and "can,' is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and 'required -are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes Source Req Go to next, Source Req Continue-' Continue-' Go to the n Source is so Continue-. Storage Tar Hydrocarbon Loadout Emissions Inventory 003 Liquid Loading Facility AIRS ID: County Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput = Potential to Emit (PTE) Volume Loaded = Barrels (bbl) per year Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = Requested Monthly Throughput= 155000 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year= Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = g :`:: ; .eeA Barrels (bbl) per year 6034, Btu/scf 1531700 scf/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L = 12.46'S*PcM/T 0 MMBTU per year 4,647 MMBTU per year 4,647 MMBTU per year A site specific stabilized hydrocarbon liquid sample must be provided to develop a site specific emissions factor. Factor Meaning Value Units Source S Saturation Factor 0,6 �//%/iw�r..�``�'%/ai��„`_" P True Vapor Pressure .,4. psa M Molecular Weight of VaporsW:';'.'...-&4,a;9'!:{ Ib/Ib-mol - T Liquid Temperature :S21t` ). Rankine L Loading Losses 3.111166164 lb/1000 gallons 0.13066897B lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.00386444 041005050 lb/bbl '1 Toluene 0:004507122 0,0005889 Ib/bbl Ethylbenzene 0;600217044 0.0000285 lb/bbl Xylene ', „ 0.001688997i'aut- 0.000220:3 lb/bbl n -Hexane 'E. 0:0112 6 7 80 4°., !:i". 0.0014724 lb/bbl -::: ,.. ,.. , 224 TMP 0.000155245 0,0000203 lb/bbl ,. .. ., . Pollutant Pollutant 11111121 IMMEIMIMMI MMINECIIIMM Hydrocarbon Loadout Uncontrolled Controlled (Ib/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) 0.119810 0.000463 0.000026 0.000202 0.000010 t t. 0.00002.7 &000001 0,000010 0,1100060 0.000001 Control Device Uncontrolled (lb/MMBtu) Uncontrolled (Ib/hhl) (Volume Loaded) (waste heat combusted) .0006 : 0:3100 Emission Factor Source Emission Factor Source 9 of 16 K:\PA\2019\19 W E0832.CP1 Hydrocarbon Loadout Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (Ihs/month) PM10 PM2.5 5Ox NOx VOC CO 0,02 0.00 0.00 0.02 0.02 3 0.02 0.00 0.00 0.02 0.02 3 lt.illl 0.00 0,00 0.00 8.00 sD 0.16 0.00 0.00 0.16 0.10 27 180.13 aA0 0.00 109..33 5,47 929 0.72 0.00 0.00 0.72 0,72 122 Hazardous Air Pollutants . Potential to Emit - Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ihs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) albs/year) Benzene Toluene Ethylbenzene Xyiene n -Hexane 224 TMP 845 0 0 845 42 986 0 0 986 49 43 0 0 48 2 309 0 0 369 10 2464 0 0 2464 123 34 Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit RACT- Regulation 3, Part B, Section 111.0.2.a (See regulatory applicability worksheet for detailed analysis) "lire loadout must operate with submerged fill and ioadosrt emissions mosi be rooted to flare to satisfy RACY, Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Based on representative sample. Fe AIRS Paint# 003 Section 09 - Inventory SCC Coding and Emissions Factors Process # 01 SCC Code 4-06-001-32 Crude Oil: Submerged Loading Normal Service (S40.6) Uncontrolled Emissions Pollutant Factor Control% Units PM10 0,00 0 lb/1,000 gallons transferred PM2.5 0.00 9 lb/1,000 gallons transferred 5Ox 0.00 0 16/1,000 gallons transferred NOx 0.00 0 lb/1,000 gallons transferred VOC 2.9 95 lb/1,000 gallons transferred CO 0.02 0 lb/1,000 gallons transferred Benzene 0.01 90 lb/1,000 gallons transferred Toluene 0.01 95 16/1,000 gallons transferred Ethylbenzene 0.00 99 l6/1,000 gallons transferred Xylene 0.00 95 16/1,000 gallons transferred n -Hexane 0.03 95 lb/1,000 gallons transferred • 224 TMP 0.00 OS 16/1,000 gallons transferred 10 of 16 K:\PA\2019\19 W E0832.CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Re lotion 3 Parts A and B-APEN and Permit Requirements 1Sourca is in she Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section Bala)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)7 3. Is the loadout operation loading less than 10,000 gallons (238 BBIs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash All? S. Isthe 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, Nax greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3(7 Toe hays tadicatnd that source is in the Son-Attolnment Aron NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, PartA, Section ll.D.1.a)? 2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)? 3. la the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oll per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY ar CO emissions greater than 10 TPY (Regulation 3, Part 0, Section 11.0.2)7 ISqueca nc3c1ras a permin 7. RACr- Are uncontrolled VOC emissions from the loadout operation greater than 20 ITl,o a Disclaimer V (Regulation 3, Part B, Section III.D.2.a) 'ate with subm need Ill and toadoan emissions must be ruutad taa reYo sail This document assists operators with determining applicability of certain requdements of the Clean AirAct, 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 dreumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language ofthe statute or regulation vn71 control. The use of non -mandatory language such as'recommend, "may,"'should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatorytorminologysuch as 'must and 'required' am intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Go to next Go bather [ Go to next. Go to next Go to next. The loadou The loadou Separator Venting Emissions Inventory 004 Separator Venting Facility AIRs ID: County Plant 004. Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Descnption: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput = big lo.susrbvstor lb� `t MMscf per year Requested Permit Limit Throughput = .931 MMscf per year Requested Monthly Throughput = MMscf per month Potential to Emit (PTE) Throughput = Process Control (Recycling) Equipped with a VRU:,-`m`i Is VRU process equipment: ;i4 2,9:3 MMscf per year Uncontrolled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the flare) Secondary Emissions - Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies .2i Btu/scf ::'scf/bbl Weight % Helium CO2 N2 methane ethane (3:00 1.68: 17.27 26:22 propane isobutane n -butane isopentane n -pentane cydopentane n -Hexane cyciohexane Other hexanes heptanes mefhylcyclohexane 224 -TM P Benzene Toluene Ethymenzene Xylenes C8+ Heavies 0:35 9 0.52' 02 1:45: 0:60 00: Qt. :24 Total VOCWt% 93.81 67.04 b/Ib-mol Displacement Equation Ex=Q"MW *Xx/C Emission Factors Separator Venting Pollutant Uncontrolled Controlled (lb/MMscf) (lb/MMscf) (Gas Throughput) (Gas Throughput) VOC 68343 208.1 241.1 15.8 1264 1899.5 3417 10.4 12.1 0.8 6_3 95.0 0.1 Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1.2 Pollutant Primary Control Device Emission Factor Source Uncontrolled Uncontrolled (Ib/MMBtu) lb/MMscf (Waste Heat Combusted) (Gas Throughput) PM10 PM2.5 16.109 16.163 1.272 .0075 50x NOx CO i0:A006 - 147.016 670.220 Emission Factor Source 12 of 16 K:\PA\2019\19W E0832.CP1 Separator Venting Emissions Inventory Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit [knits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 5Ox NOx VOC CO 0.02 0.00 0.00 0.02 0.02 4 0.02 0,00 0.00 0.02 0.02 4 0,00 0,00 0.00 0.00 0.00 0 0.22 0,00 • 0.00 0,22 0.22 37 100,12 0.00 0.00 100.12 5.01 950 0,98 0,00 0,00 0,98 0.98 107 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year( ' (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TM 610 U 0 610 30 706 0 0 706 .35 46 U 0 46 2 370 It 0 3'70 59 5565 0 it 5565 no 4 0 0 d 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVI I.B, G Regulation 7, Section XVII.B.2.e (See regulatory applicability worksheet far detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Source requires a permit Suurce is sub(vs.t: to Regulation 2, Unction XVEI,B,2, G The control device for this separator is not suhiect to Regulation 7, Section XVII.B.2.e Does the company use site specific emission factors based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AlRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissionsfactors established with this application. Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year? If yes, the permit will contain: -An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. -A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter installed and operational upon startup of this point? Edo If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This conditionwill use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling 13 of 16 K:\PA\2019\19WE0832.CP1 Separator Venting Emissions Inventory Section 08 -Technical Anal sis Notes *sed'on representative sample. Facility does not.exist AIRS Point 0 004 Section 09 - Inventory SCC Coding and Emissions Factors Process II SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control % Units PM10 16.11 fi lb/MMSCF PM2.5 16.11 0 Ib/MMSCF SOx 1.27 0 ib/MMSCF NOx 147.02 0 Ib/MidSCF VOC 69343.36 95 Ib/MMSCF CO 670.22 0 lb/MMSCF Benzene 208.09 95 Ih/MMSCF Toluene 241.12 95 Ih/MMSCF Ethylhenzene 10.0.3, 45 lb/MMSCF Xylene 126.40 95 ib/MMSCF n -Hexane 1899.46 45 Ib/MMSCF 224 TMP 1,21 95 ih/MMSC6 14 of 16 K:\PA\2019\19WE0832.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Non -Attainment Aron ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? Ions have indicated that spume is in the Noe -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section ll.0.1.a)7 2. Are total facility uncontrolled VOC emissions from the greater than 2 TPV, NM greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7 ;Source requires a permit Colorado Regulation 7, Section XVII 1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,20147 'Scarce is subject to Regulatlon 7, Sacunn XVF1.B.22, Section XVtI.e.2-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section 0VII.G - Emissions Control Altematwe Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that Is not enclosed? 'The tomrelatev'ite for this separator Is not sabred to Raguladon 7, Section XVlr.0.2.e Section XVII.B.2.e —Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is note rule or regulation, and the analysis if contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, thelanguage aftne statute or regulation will control. The use of non -mandatory language such as 'recommend," may,"should,"and -can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'squired"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Source Req . \„- Source Req lYkril ,i a4s urce is sr filiMiMilThe control 005 Fugitive equipment leaks Regulation 7 Information Operating Hours: Emission Factor Source Control Efficiency Source: Calculations 8760 hours/year Screening EFs - EPA -453/R-95-017 Table 2-8 None Service Component Type Count Emission Factor (kg/hr- source) Table 2-4 Table 2-8 Control (%) Pollutant , Mass Fraction Emissions (tpy) Reg. 3 Connectors 8467 2.00E-04 1.00E-05 0.0% VOC 0.2767 0.5563355 Flanges 1458 3.90E-04 5.70E-06 0.0% Benzene 0.0008 0.0016085 Gas Open -Ended Lines 2976 2.00E-03 1.50E-05 0.0% Toluene 0.0012 0.0024127 Pump Seals Valves 0 2824 2.40E-03 4.50E-03 3.50E-04 2.50E-05 0.0% 0.0% Ethylbenzene Xylenes 0.0001 0.0011 0.0002011 0.0022117 Other 0 8.80E-03 1.20E-04 0.0% n -Hexane 0.0059 0.0118626 Connectors 451 7.50E-06 7.50E-06 0.0% VOC 1 0.1003786 Flanges 0 3.90E-07 3.90E-07 0.0% Benzene 0.0028 0.0002811 Heavy Oil Open -Ended Lines 890 1.40E-04 7.20E-06 0.0% Toluene 0.0101 0.0010138 Pump Seals Valves 0 72 0.00E+00 8.40E-06 0.00E+00 8.40E-06 0.0% 0.0% Ethylbenzene Xylenes 0.0014 0.0136 0.0001405 0.0013651 Other 0 3.20E-05 3.20E-05 0.0% n -Hexane 0.0288 0.0028909 Connectors 4499 2.10E-04 9.70E-06 0.0% VOC 1 1.0883145 Flanges 1639 1.10E-04 2.40E-06 0.0% Benzene 0.0028 0.0030473 Light Oil Open -Ended Lines 1150 1.40E-03 1.40E-05 0.0% Toluene 0.0101 0.010992 Pump Seals 2 1.30E-02 5.10E-04 0.0% Ethylbenzene 0.0014 0.0015236 Valves 2527 2.50E-03 1.90E-05 0.0% Xylenes 0.0136 0.0148011 Other 0 750E-03 1.10E-04 0.0% n -Hexane 0.0288 0.0313435 Connectors 62 1.10E-04 1.00E-05 0.0% VOC 1 0.0081305 Flanges 0 2.90E-06 2.90E-06 0.0% Benzene 0.0028 2.277E-05 Water/Oil Open -Ended Lines 8 2.50E-04 3.50E-06 0.0% Toluene 0.0101 8.212E-05 Pump Seals Valves 0 20 2.40E-05 9.80E-05 2.40E-05 9.70E-06 0.0% 0.0% Ethylbenzene Xylenes 0.0014 0.0136 1.138E-05 0.0001106 Other 0 1.40E-02 5.90E-05 O.D% n -Hexane 0.0288 0.0002342 Emissions Summary Table Pollutant Uncontrolled Emissions Controlled Emissions Source VOC 1.75 tpy 1.75 tpy Screenin E Benzene 9.92 lb/yr 9.92 lb/yr Screenin E Toluene 29.00 lb/yr 29.00 lb/yr Screenin E Ethylbenzene 3.75 lb/yr 3.75 lb/yr Screenin E Xylenes 36.98 lb/yr 36.98 lb/yr Screenin E n -Hexane 92.66 lb/yr 92.66 lb/yr Screenin E s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s. - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 s - EPA -453/R-95-017 Table 2-8 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: f / IA/4g32 AIRS ID Number: (Z. /Ate SZ/ 001 [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: Gurtler 24HZ Site Location: NWNW Section 30, T2N, R64W Mailing Address: Code) 10188 East 1-25 Frontage Rd. (Include Zip Code) g Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: Taryn.Weiner©Crestonepr.com I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 414613 Form APCD-205 - Condensate Storage Tank(s) APEN Revision 3/2019 1 I COLORADO tmlitasmett Permit Number: AIRS ID Number: [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 traditional construction permit O Request coverage under a General Permit 0 GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) - OR ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £t 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: Condenstate Storage Tanks Company equipment Identification No. (optional): TANKS For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 12/31/2019 Normal Hours of Source Operation: 24 hours/day 7 Storage tank(s) located at: ❑✓ Exploration Ft Production (E&P) site days/week 52 weeks/year 0 Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? Yes No O ■ Are Flash Emissions anticipated from these storage tanks? • Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No I2 ■ If "yes", identify the stock tank gas -to -oil ratio: 3.77 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No ■ MI Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No D ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 21 !COLORADO :runt d rattc Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor O Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC'S & HAP's Rating: N/A Type: Enclosed Combustor Make/Model: TB D MMBtu/hr hr Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 3,034 0.025 Btu/scf MMBtu /hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 3.0 psig Describe the separation process between the well and the storage tanks: Wellhead production to hi/lo separators, bulk gas from separators to sales, bulk water from separators to tanks, bulk condensate from separators to vapor recovery tower (VRT), and then to tanks COLORADO crawl i Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 4 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the r combined) control efficiency (%reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Basis Units ° (AP -42, Mfg., etc.) Emissions (tonslyear) Emissions8 (tons/year) Emissions (tons/year) Emissions (tons/year) VOC 1.635 lb/bbl Promax — -- 1,491.94 ' 74.60 - NOx 0.068 Ib/MMbtu AP -42 — -- -- 2.27 - CO 0.31 Ib/MMbtu AP -42 — -- — 10.35 — Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 5.79E-03 lb/bbl Promax Toluene 108883 6.75E-03 lb/bbl Promax Ethylbenzene 100414 3.27E-04 lb/bbl Promax Xylene 1330207 2.52E-03 lb/bbl Promax n -Hexane 110543 1.68E-02 lb/bbl Promax 2,2,4-540841 Trimethylpentane 2.33E-04 lb/bbl Promax 5 Requested values wilt become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 Condensate Storage Tank(s) APEN - Revision 3/2019 5 I _ CaLtRAofl Ucpsrtm t DI PUCIic Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 8/23/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Supervisor Name (print) Title Check the appropriate box to request a copy of the: ✓❑ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 3/2019 COLORADO 6IAlfdg !IL -2g Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. "This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration rgthe five-year term, or when a reportable change is made (significant emissions increase, increase production, w equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: ict WF-S32 AIRS ID Number: / 23 �A 2 / 662' [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: Gurtler 24HZ Site Location: NWNW Section 30, T2N, R64W Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Rd. Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: Taryn.Weiner@crestonepr.com 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 a -mail to the address provided. 414614 Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 1 i �® COLORADO :th b [evironvvvl Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit O Request coverage under a General Permit O GP05 0 GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage Tanks PW For new or reconstructed sources, the projected start-up date is: 12/31/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks/year ❑✓ Exploration Ft Production (EEtP) site ❑ Midstream or Downstream (non E£tP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? ✓ Yes ❑ No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • A Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes ❑ No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 COLORADO 2 MA ' giant Pab ate 14a:IT fltht ✓❑ Upward O Horizontal Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit if and AIRS IDi Section 4 - Storage Tank(s) Information Actual Annual Amount (bb(/year) Produced Water Throughput: Requested Annual Permit Limits (bbl/year) 1,216,667 From what year is the actual annual amount? Tank design: ❑✓ Fixed roof N/A ❑ Internal floating roof ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of .Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) PW 2 1000 TBD 12/31/19 Est. Wells Serviced by this Storage Tank or Tank Battery6 (EftP Sites On y) API. Number Name of Well Newly Reported Well - TBD ❑ _ ❑ _ ❑ - ❑ - - ❑ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The EfrP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.11318 / -104.59867 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) PW Indicate the direction of the stack outlet: (check one) ❑ Downward ❑Other (describe): ❑ Upward with obstructing raincap Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other (describe): ....................... COLD R Abe Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 3 I Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor O Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ✓❑ Combustion Device: Pollutants Controlled: VOC's & HAP's Rating: N/A MMBtu/hr Type: Enclosed Combustor Make/Model: T B D Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 3,034 0.025 Btu/scf MMBtu/hr hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 50 psig Describe the separation process between the well and the storage tanks: Wellhead production to hi/lo separators, bulk gas from separators to sales, bulk water from separators to tanks, bulk condensate from separators to vapor recovery tower (VRT), and then to tanks Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 4IAAV eaLaeana a, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit it and AIRS ID) Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the . Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor7 Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 0.262 / lb/bbl APCD — -- 159.38 - 7.97 -' NOx 0.068 '' Ib/MMBtu AP -42 — -- — 0.31 ' CO 0.31 ' lb/MMBtu AP -42 -- -- -- 1.41 i Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor7 Actual. Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 8 (pounds/year) Benzene 71432 0.007 - lb/bbl APCD Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 ' lb/bbl APCD 2,2,4- Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 3/2019 cutoee©a 5 a,L211,17neee� 4�iruwa� AouiPl<& V11W tdrtmMciL Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit // and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP05 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. 8/23/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Supervisor Name (print) Title Check the appropriate box to request a copy of the: 0✓ Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.aov/cdphe/apcd Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 3/2019 6I COLORADO tl a th Enviroemml Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is, filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require, payment for a new filing fee. This APEN is to be used for 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.Qov/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: / 9 W Eq5 ..32 AIRS ID Number: 123 1 Algzi 63 [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: Gurtler 24HZ Site Location: NWNW Section 30, T2N, R64W Mailing Address: p Code) 10188 East 1-25 Frontage Rd. (Include Zip Code) g Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Taryn Weiner (303) 774-3908 Taryn.Weiner@Crestonepr.com 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. 414615 Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 1 n.of?uric Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) OR - ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Ft 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 Loading from Condensate tanks Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 12/31/2019 Will this equipment be operated in any NAAQS nonattainment area? IN Yes • No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • IN Does this source load gasoline into transport vehicles? Yes No ■ 19 Is this source located at an oil and gas exploration and production site? Yes No Igl • If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No 0 • Does this source splash fill less than 6750 bbl of condensate per year? Yes No I2 • Does this source submerge fill less than 16308 bbl of condensate per year? Yes No I IN Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 21 COLORADO Hew'1Rb LnvRbnmwJ Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate O Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1,825,000 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: tank trucks (e.g. "rail tank cars" or "tank trucks") bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor:60.0 0.60 Average temperature of bulk liquid loading: .F True Vapor Pressure: 4. Psia @ 60 ° F Molecular weight of displaced vapors: 5 ^ . `+ lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 COLORADO 3 , AV. Dep,rtm.eee,Ir.tk Ncalh b EP,,bdem.[rl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS 101 Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.11318 / -104.59867 P Disc'. eiiti xY cr a Y now Rate (ACF, V ibcity t/sec) LOAD -1 Indicate the direction of the stack outlet: (check one) El Upward O Horizontal O Downward O Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular Interior stack diameter (inches): O Other (describe): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. O Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOC's & HAP's Rating: N/A Type: Enclosed Combustor MMBtu/hr Make/Model: TBD Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A °F Waste Gas Heat Content: 3,034 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 0.025 MMBtu/hr O Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 CeLORAatis 4 I d w.�.�xrgi„ t Permit Number: AIRS ID Number: [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 ombined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO), NO,, CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane ❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL ❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limtt(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM Sox NOx 0.068 - Ib/MMBtu AP -42 -- -- -- 0.21 CO 0.31 — Ib/MMBtu AP -42 -- -- -- 0.98 VOC 0.120 j lb/bbl AP -42 -- -- 109.34 — 5.47 -- Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Service (CAS) Number Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/ ear Y ) Controlled Emissions6 (pounds/year) Benzene 71432 4.63E-04 " lb/bbl Eng. Est. Toluene 108883 5.40E-04 i lb/bbl Eng. Est. Ethylbenzene 100414 2.61E-05 i lb/bbl Eng. Est. Xylene 1330207 2.02E-04 / lb/bbl Eng. Est. n -Hexane 110543 1.35E-03 ' lb/bbl Eng. Est. 2,2,4- ' Trimethylpentane 540841 1.86E-05 lb/bbl Eng. Est. Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN Revision 3/2019 GOL0RA0d} - AWAIT, 6,,MironeiG. Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. 14141,, WeL,„, 8/23/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Supervisor Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance QQ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 61 COLORADO Ggaannant al Pnctic Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: I WEpg32 [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS ID Number: 1Z3 ittOg2, /OOL/- Section 1 - Administrative Information Company Name': Crestone Peak Resources Operating, LLC Site Name: Gurtler 24HZ Site Location: NWNW Section 30, T2N, R64W Mailing Address: 10188 East 1-25 Frontage Rd. (Include Zip Code) g Firestone, CO 80504 Site Location Weld County: NAIC5 or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: Taryn.Weiner@Crestonepr.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. 414616 Form APCD-211 - Gas Venting APEN - Revision 3/2019 1 I ......................... COLGRA O h. .an, of Public It.:vtth 6 EnvUaI r* tl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR - ❑ MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment ❑ Change company name3 0 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 - ID 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: when VRU's are offline Low pressure separator venting to combustor Company equipment Identification No. (optional): Buffer For existing sources, operation began on: For new, modified, or reconstructed sources, the projected start-up date is: 12/31/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? days/week weeks/year ❑✓ Yes O Yes 0 Yes ❑ No 0 No ❑ No Form APCD-211 Gas Venting APEN - Revision 3/2019 /yAA COLORADO 2 I �� Qo "�^`dRWlc x�:m 6 ¢o.wn.i Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑ Yes Gas Venting Process Parameterss: Liquid Throughput Process Parameterss: Vented Gas Properties: ❑✓ No Vent Gas Heating Value: 2 162 I BTU/SCF Requested: 2.93 MMSCF/year Actual: -- MMSCF/year -OR- Requested: bbl/year Actual: bbl/year Molecular Weight: 38.17 VOC (Weight %) 67.86 Benzene (Weight %) 0.21 Toluene (Weight %) 0.24 Ethylbenzene (Weight %) 0.02 Xylene (Weight %) 0.13 n -Hexane (Weight %) 1.89 2,2,4-Trimethylpentane (Weight %) 0.001 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX & n -Hexane, temperature, and pressure) s Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 3/2019 COLORADO 3 I A bra Wnl MClic Ha. b rrv,q.W.t,bl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS IDi Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.11318 / -104.59867 O eratar P Stack ID to Discharge Heighfi. Above Ground Level e (Feet, Temp („F) ` Ftow Rai a C (ACFM) el�city fft/sec) Sep. Vent 20 Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ® Circular ❑ Other (describe): Interior stack diameter (inches): ❑ Upward with obstructing raincap 48" Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ VRU: ❑✓ Combustion Device: Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: Rating: Make/Model: VOC's & HAP's N/A MMBtu/hr Type: Enclosed Combustor Make/Model: TBD Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: N/A Waste Gas Heat Content: 2 162 Btu/scf 9 MMBtu/hr Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 0.025 Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 ••• Gas Venting APEN - Revision 3/2019 41 CO LOSADO t�p.:rtrt_n� - Taunt wume cn�irev..+am Permit Number: AIRS ID Number: [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 uVCI CU tul LVnIVu icu, Pollutant cv. Iuv. ... I"....-,..., ,,.._......_._ , Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SO NO, CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP 42 Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions 6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NO„ 0.068 lb/MMbtu AP -42 -- -- -- 0.22 '- CO 0.31 lb/MMbtu AP -42 — -- -- 1.01 VOC 68.34 ' lb/Mscf Eng. Est. -- -- 100.00 '- 5.00 --- Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Source Uncontrolled Controlled Abstract Chemical Name Service (CAS) Number Uncontrolled Basis Units (AP 42, Mfg., etc.) Emissions (pounds/year) Emissions6 (pounds/year) Benzene 71432 0.21 -- lb/Mscf Eng. Est. Toluene 108883 0.24 - lb/Mscf Eng. Est. Ethylbenzene 100414 0.02 / lb/Mscf Eng. Est. Xylene 1330207 0.13 ' lb/Mscf Eng. Est. n -Hexane 110543 1.90 ' lb/Mscf Eng. Est. 2,2,4- Trimethylpentane 540841 0.001 ' lb/Mscf Eng. Est. Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 Gas Venting APEN - Revision 3/2019 5I z5Aua m tr uF Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. %�� 1j `i' {/�/-'u/l 8/23/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Supervisor 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: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 3/2019 -- COLORADO 6 I A� d� wvmarnmronment Fugitive Component Leak Emissions APEN Form APCD-203 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for fugitive component leak emissions only. If your emission source does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/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: / civvgo832 AIRS ID Number: 1 Z3 //10E21605 -- [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: Gurtler 24HZ Site Location: NWNW Section 30, T2N, R64W Mailing Address: 10188 East 1-25 Frontage Road (Include Firestone, CO 80504 Site Location Weld County: NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.weiner@crestonepr.com 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. 414617 Form APCD-203 - Fugitive Component Leak Emissions APEN Revision 3/2019 • coLORAD* 1, Aq',... ol, Nu'.IF b Crt�ltOrtm¢vl Permit Number: AIRS ID Number: / / [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 0 Change company name3 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below) - OR ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information Company equipment Identification No. (optional): FUG For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 12/31/2019 ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Facility Type: ❑✓ Well Production Facilitys 0 Natural Gas Compressor Stations 0 Natural Gas Processing Plants 0 Other (describe): hours/day days/week weeks/year 5 When selecting the facility type, refer to definitions in Colorado Regulation No. 7, Section XVII. Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 3/2019 2 I COLORADO Ccp n mna of Rmuc Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS IDI Section 4 - Regulatory Information What is the date that the equipment commenced construction? TBD 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 compressors ❑✓ 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? p Yes ❑ No Is this equipment subject to Colorado Regulation No. 7, Section XVII.B.3? p 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. Stream VOC (wt %) Benzene (wt %) Toluene (wt %) Ethylbenzene (wt %) Xylene (wt %) n -Hexane (wt %) 2,2'4 Trimethylpentane (wt %) Gas 27.67 0.08 0.12 0.01 0.11 0.59 0.001 Heavy Oil (or Heavy Liquid) 100 0.28 1.01 0.14 1.36 2.88 0.03 Light Oil (or Light Liquid) 100 0.28 1.01 0.14 1.36 2.88 0.03 Water/Oil 100 0.28 1.01 0.14 1.36 2.88 0.03 Section 6 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.11318 / -104.59867 Attach a topographic site map showing location COLORADO Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 3/2019 3 rLmtihsLnv,w.nme,:i Permit Number: AIRS ID Number: / / [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% light liquid pump ❑ Quarterly Monitoring - Control: 70% gas valve, 61% light liquid valve, 45% light 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: O No LDAR Program 6 Attach other supplemental plan to APEN form if needed. Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 4of PuKtc ® COLORAD* 4 Issu Heal* FnWronmMut Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit II 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 emissions. 0✓ Table 2-8 (< 10,000ppmv) was used to estimate emissions. Use the following table to report the component count used to calculate emissions. The component counts listed in the following table are representative of: ❑✓ Estimated Component Count El Actual Component Count conducted on the following date: Service Equipment Type Connectors Flanges Open -Ended Lines Pump Seals Valves Other9 Gas Count8 8,467 1,458 2,976 0 2,824 0 Emission Factor 2,20E-05 1.26E-05 3.31 E-05 5.51 E-05 Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source Heavy Oil (or Heavy Liquid) Count8 451 0 890 -- 72 0 Emission Factor 1.65E-05 1.59E-05 -- 1.85E-05 Units lb/hr/source lb/hr/source -- lb/hr/source Light Oil (or Light Liquid) Count8 4,499 1,639 1,150 2 2,527 0 Emission Factor 2.14E-05 5.29E-06 3.09E-05 1.12E-03 4.19E-05 Units lb/hr/source lb/hr/source lb/hr/source lb/hr/source lb/hr/source Water/Oil Count8 62 0 8 0 20 0 Emission Factor 2.20E-05 7.72E-06 2.14E-05 Units 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. Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 3/2019 5 I eOLORAOO L,pa�-m: of �rssmf coaxar..., Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already 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? N/A Use the following table to report the criteria pollutant emissions and non -criteria pollutant (HAP) emissions from source: Use the data reported in Section 8 to calculate these emissions. Chemical Name CAS Number Actual Annual Emissions Requested Annual Permit Emission )11 Limit(s)11 Uncontrolled (tons/year) Controlled 10 (tons/year) Uncontrolled (tonslyear) Controlled (tons/year) VOC -- -- 1.75 - 1.75 Does the emissions source have any actual emissions of non -criteria pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year? Yes Q✓ No If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source: Chemical Name CAS Number Actual Annual Emissions Limit(s)11 Requested APermit Emission Uncontrolled (lbs/year) Controlled10 (lbs/year) Uncontrolled (lbs/year) Controlled (lbs/year) Benzene 71432 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2,2,4 Trimethylpentane 540841 Other: 10 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 11 Requested values will become permit limitations. Requested limit(s) should consider future process growth, component count variability, and gas composition variability. �. t1 RA bti Form APCD-203 - Fugitive Component Leak Emissions APEN - Revision 3/2019 6 I Permit Number: AIRS ID Number: / / [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. 8/23/2019 Signature of Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Supervisor Name (print) Title Check the appropriate box to request a copy of the: ❑r Draft permit prior to issuance �✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-203 Fugitive Component Leak Emissions APEN - Revision 3/2019 ©+lw COLORADO 7 I �! xersma[rvironmrr.� Hello