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Home My WebLink About20195094.tiffRECEIVED Rib I;cRev:e(A) COLORADO Department of Public Health & Environment Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 December 4, 2019 Dear Sir or Madam: DEC 1 2 2019 WELD COUNTY COMMISSIONERS On December 5, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for Crestone Peak Resources Operating, LLC - Ruegge 4H -N165 Battery . 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 Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director CC: PLCrP), Hl,-,(t-K),QU!(Tri/ERIC-/CK)i os(sM) 12/13/19 2019-5094 40,,, Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Crestone Peak Resources Operating, LLC - Ruegge 4H -N165 Battery - Weld County Notice Period Begins: December 5, 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: Ruegge 4H -N165 Battery Exploration Ft Production Well Pad SESW Quadrant of Section 4, Township 1N, Range 65W Weld County The proposed project or activity is as follows: Crestone Peak Resources Operating, LLC (Crestone) currently owns and operates the Stelling Battery. Crestone has requested a name change for this facility, from "Stelling Battery" to "Ruegge 4H -N165 Battery" as well as modifications to the currently permitted sources at the facility. The existing Stelling facility consisted of seven wells, five of the wells have been plugged and abandoned. The remaining two wells flow to the newly constructed facility along with eighteen newly wells that came online October 2018. The existing battery and all associated equipment were removed, and a new facility was constructed in its same location. Crestone has requested to permit condensate storage, produced water storage, condensate loadout and low pressure gas venting in this permitting action. 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 13WE1392.CP2 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 COLORADO Department at Public Health @ Envircmnent • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: James Ricci Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 21 COLORADO Department efPublic Health & Envircnnwnt 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 CONSTRUCTION PERMIT Permit number: 1 3WE1 392 Issuance: 2 Date issued: )O( Issued to: Crestone Peak Resources Operating, LLC Facility Name: Plant AIRS ID: Physical Location: County: General Description Ruegge 4H -N165 Battery 123/3815 SESW Quadrant of Section 4, Township 1N, Range 65W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID ' AIRS Point ' Equipment Description . Emissions Control Description LOAD -1 003 Loadout of condensate from storage vessels to tank trucks by submerged fill Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C. R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1 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.) 2. 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 Page 1 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4. ) 3. 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 4. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation Number 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC CO LOAD -1 003 8.6 1.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits: Facility -wide emissions of each individual hazardousair 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. 5. 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. 6. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LOAD -1 003 Enclosed Combustor with a Manufacturer Guaranteed Control Efficiency of 98% VOC and HAP Page 2 of 8 Jett - COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 7. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD -1 003 Condensate Loaded 1,449,050 barrels Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total.By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month ' and keep a compliance record on site '` or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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.) 9. This ` source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks must be conducted by submerged fill and emissions must be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2) 11. 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. 12. The owner or operator must follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E): a. The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections must occur at least monthly. Each inspection must be documented in a log available to the Division on request. Page 3 of 8 COLORADO Aix Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado b. All compartment hatches at the facility (including thief hatches) must be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers must be weighted and properly seated. d. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs must be set to release at a pressure that will ensure flashing, working and breathing losses are not vented through the PRD under normal operating conditions. e. Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. 13. 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 Include devices to prevent the release of vapor from vapor recovery hoses not in use. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING £t MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (O£tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your o&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. All previous versions of this permit are cancelled upon issuance of this permit. 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C. • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 4 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level; reported on the last APEN submitted to the Division. Whenever there is a change in the owner or operator of any facility, process, or activity; Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or • No later' than 30 days before the existing APEN expires. 19. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all Page 5 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in. the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division airevokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative,civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 May 24, 2013 Issued to Encana Oil Et Gas (USA), Inc. Issuance 2 This Issuance Issued to Crestone Peak Resources Operating, LLC for condensate loadout at a synthetic minor facility in the non -attainment area Page 6 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 ail of the criteria set forth in Part 11.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 603 30 n -Hexane 110543 5231 262 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- NOx 2.79 x 10-4 2.79 x 10-4 AP -42 Chapter 13.5 Industrial Flares -- CO 1.27 x 10"3 1.27 x 10"3 -- VOC 2.36 x 10"1 1.18 x 10"2 PS Memo 14-02, State Approved 71432 Benzene 4.16 x 10"4 2.08 x 10-5 110543 n -Hexane 3.61 x 10"3 1.81 x 10-4 Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599' Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 6: Received Date: Review Start Date: James Rim 12/28/2018 4/24/2019 Section 01- Facility Information Company Name: Crestone Peak Resources Operating, LLC County AIRS ID: 123 Plant AIRS ID: 3815 Facility Name: Ruegge 4H-9165 Battery Location: SESW Quadrant of Section 4, Township 1N, Range 65W County: Weld County Type of Facility: 'Exploration'& Production Weil Pad What industry segment? 6ilI,&cNatural Gas Production .&:Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 -Emissions Units In Permit Application Particulate Matter (PM) ❑� Quadrant Section Township Range SESW Ozone (NOx & VOC) N fi5 AIRS Point 6 Emissions Source Type Equipment Name Emissions Control? Permit R Issuance q Self Cert Required? Action Engineering Remarks 001 CortdensateTank TANKS - Yes - GP01 - 2 No. --- Permit - Modification Package 391741 002 PtbduredWater Tank °'' PW Yes - � :-19WE0028.CP1 1 Yes Permit MI issuance _ 003 Liquid Loading LOAD -1 Yes 13WE1392.CP2 "2 Yes Permit: Modification 012 SeparatorVenting - Buffer Yes -19WE0052.CP1 1 __ Yes permifrinitiol Issuance --r Section 03 - Description of Project Crestone Peak Resources Operating, LLC (Creston) currently owns and operates the Stelling Battery. Crestone has requested a name change for this facility, from "Stelling Battery" to' Ruegge 4H -N365 Battery" as well as modifications tothhecurrently permitted sources atthe facility. The existing Stelling facility consisted of seven wells, five of the wells have been plugged and abandoned. The remaining two wells flow to the newly constructed facility along with eighteen newly wells that came online October 2018. The existing battery and all associated equipment were removed, and a new facility was constructed in its same location. - ' The twenty (20) wells on site each produce through high/low pressure separators followed by a bulk separator. Hydrocarbon liquids from the bulk separator are routed through a vapor recover. tower (VRT) before being sent to the condensate storage tanks, Produced water from the high/low pressure separators is routed directly to water: storage tanks. Gas from the low- pressure separators are routed to VRUs. In the event the VRUs are offline, gas is sent to enclosed combustors for control, Storage tank emissions` are `routed to enclosed flares for control. Can -; from the high-pressure separators and VRT is directed to the sales line via VRUs. Produced water is transported from the facility via truck. Condensate istransferred out ofthe facility by Additionaly, the facility operates eight enginesthathave a site rated horsepower of less Part B t l than 50' hp and are ' categorically exempt from permitting per Colorado Regulation 3,, S-ct II,D.1c-(iii , Thefacility - - - -'"`- j has two additional engines covered Unver GP02s. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requestii Section OS - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes Minor Permit', 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) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) zYes SO2 NOx CO VOC PM2.5 PM10 TSP HAPs LIE ❑ ❑ ❑ ❑ O OOOO 000 ❑ No 502 NOx CO VOC PM2.5 PM10 TSP HAPs O 00000 O ODOO 000 ❑ ❑ 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 leadout controlled? Collection Efficiency: Control Efficiency: Requested Overall VOC & HAP Control Efficiency %: 95.00 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 = 0,0,50 Barrels (bbl) per year Barrels (bbl) per year 9,05D:, Barrels (bbl) per year Secondary Emissions -Combustion Device(s) Heat content of waste gas= Btu/sd Volume of waste gas emitted per year = £?93982 scf/year Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Sectiem04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? Actual Volume Loaded While Emissions Controls Operating = 1i! Requested Monthly Throughput= 223070 Barrels(bbl) per month 5,342 MMBTU per year 5,942 MMBTU per year 9,2.90 MMBTU per year The d ult e Emission Factors Hydrocarbon Loadout Pollutant Uncontrolled Controlled ph/Bbl) (Ib/bbl) (Volume Loaded) (Volume Loaded) 1..18E-02 2.081 - Emission Factor Source VOC 2.35E-01 Benzene n -Hexane 4 Pollutant Control Device Uncontrolled (lb/R/IMBtu) Uncontrolled (Ib/bbl) (Volume (waste heat combusted) Loaded) Emission Factor Source PM10 PM2.5 3.05t -US 3,001.05 2.41E -OH SOx Nog CO 0f0 BD,.,., .. 2.79E-04 1.27E-03 it Barrels (bbl) per year <— From Applicant s factors may he used to estimateentissions. 2 of 4 K:\PA\2013\13 W E1392.CP2 Hydrocarbon Loadout Emissions Inventory Section 05- Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 SOx NOx VOC CO 0.0 0,0 0,0 0,0 0,0 4 0.0 0,0 0.0 0,0 0.0 4 0,0 0.11 0.0 0.0 0.11 0 0.3 0.3 0.3 0.3 0,3 54 1"/1,0 371.0 5.5 171,1) 0,6 1454 1.4 1.4 1.4 1.4 1.4 245 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 n -Hexane 003 603 30 603 I 30 5231 5231 262 5231 I 262 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B RACi- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheet for detailed analysis) Source requires a penult The loadout must operate with submerged fill and loadoot emissions must be routed to flare to satisfy RACE. 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 toteMotes e c ¢Lfi I xallysubm [t dap s r z d t s pie th two fl d t t mate emissions However 'hrough the review of tins application tt was found that ern i sio Section 09 - Inventory SCC Coding and Emissions Factors AIRS Pointy' Process 0 SCC Code 003 01 4-06-001-32 Crude Oil: Submerged Loading Normal Service (0=0.6) Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons transferred PM2.5 0.00 0 lb/1,000 gallons transferred SOx 0,00 0 lb/1,000 gallons transferred NOx 0.01 0 lb/1,000 gallons transferred VOC 5.6 95 lb/1,000 gallons transferred CO 0.05 0 lb/1,000 gallons transferred Benzene 0.01 95 lb/1,000 gallons transferred Toluene 0,00 95 lb/1,000 gallons transferred Ethylbenzene 0.00 05 lb/1,000 gallons transferred Xylene 0,00 95 16/1,000 gallons transferred n -Hexane 0,09 95 lb/1,000 gallons transferred 224 TMP 0,00 95 lb/1,000 gallons transferred 3 of 4 K:\PA\2013\13 W E 1392. CP2 Hydrocarbon Loado0t Regulatory Analysis Worksheet wosseertIon3 Pam. canna a•+ana v.tm6 a.,v6em.ma FtEE 1 runwn0Modswal emslonr Non any[NNW Indivhual source miser den 1TPT PeguWtlnn. PartA, WITonl1.0.1a15 pollutants Mm 1 a and production sleMEr.N IMII6 lRewmmo&5an6, semen 6.6.1.65 3. ANN tvaa°ehalnelesstzn10,o66plbns(v6661slorMod padaroossoNuaaaage0adsi a. is de le.ama operator, hiding less man 6,750 Wis per maim con dense Me splash con 5. ¢melmdouromothohadmgless tan 16,366 ems per year of condenasovieauetmrgad Al procedures 6. Am total NW, uncontrolled WCemlssbns Nesterdan5Trl. NCI greeter Man 10 TM NCO enMsbnsNeater than lain l6egubdon&PertA MONA ODOR IAN n< olliNtaFrsaIsInthaNsmnt:..nosstA„ NON -ATTAINMENT 1. Ann o-nTed emis.lansfrom ens NM. pollutan¢mmdb md;vbwl source gan.than1TM (Regulation. Pert, 2cwnI1.6.1.,P atenesplorstlon and product...Ie. MO ITTM (eguA. 1.51551, MWITM1.6.i115 Is he eoperaronwd 6t5166No m66151°Tula. m Pe ear on an ohm. stsIoNemh5 Me loSOSucoperatlenbidding lcs ban 6,350600 permar olc°naens.evlasptash 6115 M e loo onhadng lass mar mergedpnacedure 6. Are e¢ledlNT uncontrolled VOL em0sl°ns lmmdsEr greater kW lTIM.NOagreser ManSTPyorCO emissions greaser than 10TM@esulation 5, Part&Salon llL]R amAr55i Rd 4' 7. PAR -Are unconbolled VOC essMions hamda hale.opeaaon Eraser Nan 50 ray (Regulation 5, Part6, SPAWN ll10.15P rho 1°a.oursoot 0tie.z_ Wit mtarmasu5111and Meow! ATMs,. berm., "m6nesosa.is:ahAC.. olsemmer ITb 0ocumsntasslstsopsratrs with celemYmrgapplka00011d cadain requkamenls MUlu Clean AOA* Js Impbmantng In.,...) Airt.fily Cbnbol Comr. an reguOlbns Thlsdewment isnwta rule wregulafbn.aM the arrays@6 cntaireneyrletapp5roepankaOrsAua6'en 6600]5,356, Uua?Mirdtsl lads andtimrvevfa ThOdawrren(does naf chanp w..stiN*Many 056, reWOlion, waryodwbpalrybitdngreptusaranl endb no(leWNe...30O.1n Ina event of any conAkt 0&vase Me leyuage NNis aowmantantl Ne bnguape olNe Chen AlrAct, ils 0 p**0ntMgr Wletbns and Air@.aliryControl Cammissbn rew0liarK the krlgw5s olrhe shlule arreguklbn 0(6 wnlml The 0 0 otnonsarbabry HrlgueW xucn as'recornmarN."may,' 'slcud,`and `can,"1.000080 b desn0e APCO inlerprelalbr 66 5 taxmrrenc0ldns. MarMebrylamirlobga such as'mas?6955apulred'asz Wended to tleuri060.roll drepulrmrenls under UIe IapW of Me Jaen Air AG asp PirCue010 Cmbd CW 00$00 reWOfbre, 0uf Mis dcwaenf does real es 0000*10 0y blsgngnequvarenlsn and of0s0. Go so Ascalon 6 Go. nesoomelko nemoueston nev¢Tued°n The loadoutrequIress permit Z.WA wrtsubmersed Aland Nash. emissions must Ise Touted esonemmsaSO RAcr.nn°tn°ne°Ima,°PAeranaMle 1lregeretl.na p. COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit number: Date issued: Issued to: CONSTRUCTION PERMIT 1 9WE0028 Issuance: 1 Crestone Peak Resources Operating, LLC Facility Name: Ruegge 4H -N165 Battery Plant AIRS ID: 123/3815 Physical Location: SESW Quadrant of Section 4, Township 1N, Range 65W County: Weld County General Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description • Emissions Control Description PW 002 Two (2) 500 barrel fixed roof storage vessels used . to store produced water Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify Page 1 of 8 IS COLORADO Air Pollution Control Division Department of PublicHealth & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. Theoperator must retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION! LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type VOC CO PW 002 6.5 1.0 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit Page 2 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled PW 002 Enclosed Combustor with a Manufacturer Guaranteed Control Efficiency of 98% VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit PW 002 Produced Water Throughput " 985,500 barrels Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Page 3 of 8 1� COLORADO Air Pollution Control Division Department of Public Health B Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit, prior to May 1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING £t MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (0EM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&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 16. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. All previous versions of this permit are cancelled upon issuance of this permit. 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, II.C.) Page 4 of 8 ic„, COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • 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 submittedto the Division Whenever there is a change in the owner or operator of any facility, process, or activity; or Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or Whenever a permit limitation must be modified; or No later than 30 days before the existing APEN expires.' 20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all Page 5 of 8 COLORADO Aix Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permitmay be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration.. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC for produced water storage at a synthetic minor facility in the non -attainment area. Page 6 of 8 vele COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled'. Emissions (lb/yr) 002 Benzene 71432 6899 345 n -Hexane 110543 21681 1084 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source -- NOx 4.61 x 10-4 4.61 x 10-4 AP -42 Chapter 13.5 Industrial Flares -- CO 2.10 x 10-3 2.10 x10-3 -- VOC 2.62 x 10-' 1.31 x 10-2 PS Memo 14-03, State Approved 71432 Benzene 7.00 x 10-3 3.50 x 10-4 110543 n -Hexane 2.20 x 10-2 1.10 x 10-3 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. Page 7 of 8 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of VOC 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: httq://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A"- Subpart UUUU NSPS Part 60, Appendixes AppendixeA - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 8 of 8 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: James Ricci Package #: =391745,,;'.,. Received Date: 12/2312018 Review Start Date: 4/24/2013 Section 01- Facility Information Company Name: Crestone. Peak Resources Operating, LLC County AIRS ID: 123-`. Plant AIRS ID: 381S ' Facility Name: Ruegge 4H -N165 -Battery Location: SESW Quadrant of Section 4, Township 1N, Range 65W County: Weld County Type of Facility: 841k:ration & Production Well-Ped What industry segment? Oil NaturalCas.production &Processing , Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) O Quadrant Section Township Range 553W Ozone (NOx & VOC) 5 AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TANKS Yes Permit Mcrdificatron Package 391741 002 P,roduced Water Tanis = PW Yes 19WE002B.CP1 1 _ Yes Perm Itsitiat Issuance 003 Liquid Loading LOAD -2 Yes 13WE1392':CP2 2 ' Yes " Permit Modification 012 • .. Separater Venting .. .... -' Buffer Yes 19W E0052.CP1 1 Yes Permit €nitisl' Issuance - • _ Section 03 - Description of Project Crestone Peak Resources Operating, LLC (Crestone) currently owns and operates the Stelling Battery. Creston has requested a name change for this facility, from "Stelling Battery' to "Ruegge•••.•i 4H -N165 Battery' as well as modifications to the currently permitted sources at the facility. The existing Stelling facility consisted of seven wells, five of the wells have been plugged and abandoned. Theremaining two wells flow to the newly constructed facility along with eighteen newly wells that came online October 2018. The existing battery and all associated equipment • The twenty (20) wells on site each produce through high/low pressure separators followed by a bulk separator. Hydrocarbon liquids from the bulk separator are muted through a vapor recover tower (VRT) before being sent to the condensate storage tanks. Produced water from the high/low pressure separators is routed'. directly to water storage tanks. Gasfrom the low-pressure separators are routed to VRUs. In the event the VRUs are offline, gas is seotto enclosed combustors for control. Storage tank emissions are routed to enclosed flares for control. Gas from the high-pressure separators and VRT is directed to the sales line via VRUs. Produced water is transported from the facility via trtx:k.Condensate is transferred out of the facility either by pipeline or truck. .., Additionaly, the facility operates eight engines that have a site rated horsepower of less than 50: hp and are categorically exempt from permitting per Colorado Regulation 3, Part S, Section II.D.1-a(iii). The facility has two additional engines coveredtinver GPO2s. - - - - Section 04 - Public Comment Requirements IsPublic Comment Required? Yes - If Pyes, why? Requesting Syntlietic Minor i Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? `• If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) . Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 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 here: 502 NOx CO Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) VOC PM2.5 PM10 TSP • E HAPs ❑ ❑ Produced Water Storage Tank(s) Emissions Inventory 002 Produced Water Tank Facility AIRs ID: 2. County Plant - Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device --- Endosed CprnBusfonwith Uanufactgrer,5uaranteed Control Efficiency of 98°/q.,: Description: Requested Overall VOC & HAP Control Efficiency %: Two {y};;O9har Hoed:roof storage vessels use: duced water Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Secondary Emissions - Combustion Device(s) Heat content of waste gas= "° '2048 ,reap` Btu/scf Volume of waste gas emitted per BBL of liquids scf/bbl produced= Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device= PTE heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year - Barrels (bbl) per year Section 04- Emissions Factors & Methodologies Wil this storage tank emit flash emissions? Actual Produced Water Throughput While Emissions Controls Operating = Requested Monthly Throughput= 83700 Barrels (bbl) per month 6,679 MMBTU per year 6,679 MMBTU per year 6,679 MMBTU per year Emission Factors Produced Water Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Produced Water Throughput) (Produced Water Throughput) VOC 1.31E-02 3.50E-04 1.10E-03 Benzene n -Hexane Emission Factor Source Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (lb/MMBtu) (Ib/bbl) (waste heat combusted) (Produced Water Throughput) PM10 PM2.5 0.0001 0.0001 NOx CO (~ 'W3ITf0 h007S, .: fir. 4.61E-04 2.10E-03 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) I Requested Monthly Limits Controlled (lbs/month) VOC PM10 PM2.5 NOx CO 129.1 129,1 63 128.1 6.5 1096 0.0 0.0 0.0 0.0 0.0 4 0.0 0.0 0,0 0.0 0.0 4 0.2 0.2 0.2 0,2 0.2 39 1.0 1.0 1,0 1.0 1.0 176 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (lbs/year) Benzene n -Hexane 6899 6899 340 61x9$ 345 21691 21681 I 1084 21681 1084 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Source requires a permit Regulbtion 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not sub(ect to NSPS 0000 (See regulatory applicability worksheet for detailed analysis) 2 of 4 K:\PA\2019\19 W E0028.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 for additional guidance on testing. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section OB - Technical Analysis Notes Or gmally perm-₹ted under a OP05 then drepp� The applicant originally submitted a pressor, been representative of the entire process since er sample -that was flashed t "stio r is separated in mwr ple st ges at varlet, Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # 5CC Code 002 01 4-04-003-1S 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/1,000 gallons liquid throughput Toluene 0.00 95 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput Xylene 0.00 95 lb/1,000 gallons liquid throughput n -Hexane 052 95 lb/1,000 gallons liquid throughput 224 TMP 0.00 95 lb/1,000 gallons liquid throughput 3 of 4 K:\PA\2019\19WE0028.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 atone of these facilities, please review NSPS Kb. Colorado Re, ulation 3 Ports A and B- APEN and Permit Requirements (Source is in the Nen-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPV (Regulation 3, Part A, Section II.D1.a)? 2. Is the operator claiming less than 1% crude oil and Is the tank located at a non-commercial facility for processing og and gas wastewater? (Regulation 3, Part B, Section II,D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NCO greater than 10TPV or CO emissions. greaterthan 10 TPV (Regulation 3, Part B, Section 11.0.3)? 'you hew indicated that source is in the Nan-Attolnetent Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TP? (Regulation 3, PartA, Sector lI.D.1.a)7 . . 2. Is the operator claiming less than 1% crude oil and Is the tank located et a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part e, Sectiontl.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2TPV, N0x greater than 5 TPV or CO emissions greater than to TPV (Regulation 3, Part B, Section 11.0.217 'Source requires a "malt Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions" of this storage tank equal to or greater than 6 tons per year VOC? 'Sterage tank is subject to Reguiei on 7, Suction XVit, ll, C.1 A 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 XVI I.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabillzed"liquids? If no, the following additional provisions apply. 'Storage rank 10 uvu la,? to Regulation 7, Section YVII.C.2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, 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 all and natural gas production segment, nateral gas processing segment or natural gas transmission and storage segment of the Industry? 2. Was this produced water storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 20157 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? ISteregu Tank is not subject to. NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards far VOC §60.5413 - Testing and Procedures §80.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c)- Cover and Closed Vent System Monitoring Requirements §fie.5417-Control Device Monitoring Requirements• [Note: lf a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tans per -year VOC an the applicability determination date, It should remain subject to NSPS 0000 per 60.5365(e)(2) even K potential VOC emissions drop below Stens per year] - RACT Review RACT review is required If Regulation 7 does not apply AND If the tank Is In the non -attainment area. If the tank meets both criteria, then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Cream Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a nile 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 orsubstitute 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„ lie implementing regulations, and Air Qualify Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatary 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 10 describe controlling requirements under the terms of the Clean Air Acf and Air Qualify Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes $i$7 Continue-' Go to the n Storage Tar row Source Req Go to next. Source Req Continue-' Continue - Go to the n Source I5 st 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: 19WE0052 Issuance: 1 Date issued: )O( Issued to: Crestone Peak Resources Operating, LLC Facility Name: Plant AIRS ID: Physical Location: County: General Description:' Ruegge 4H -N165 Battery 123/3815 SESW Quadrant of Section 4, Township 1N, Range 65W Weld County Weil Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control Description Buffer 012 Buffer house comprising of low pressure gas vented during VRU downtime Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act, (C. R. S. 25-7-101 et seq), to this specific ' general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self - certify compliance as required by this permit may be obtained online at Page 1 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado www.colorado.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. Within thirty days (30) after issuance of this permit, 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. Until the flow meter is installed, the operator must monitor and record condensate/crude produced through the separator and estimate the gas flow rate based on standard cubic feet (scf) per barrel (bbl) of 199.6 scf/bbl estimated in the permit application. 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 providefinal 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.) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type VOC CO Buffer 012 10.0 2.0 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Page 2 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled Buffer 012 Low pressure gas from the buffer house is sent to an enclosed combustor during Vapor Recovery Unit (VRU) downtime VOC and HAP PROCESS LIMITATIONS AND 10. 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 Equipment ID AIRS Point Process Parameter Annual Limit Buffer 012 Natural Gas Venting 5.89 MMSCF 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. 11. Upon installation of the flow meter, 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 Page 3 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado compliance with the process limits contained in this permit and to calculate emissions as described in this permit. 12. The owner or operator must continuously monitor and record Vapor Recovery Unit (VRU) downtime while emissions are routed to the control device. STATE AND FEDERAL REGULATORY REQUIREMENTS 13. 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) 14. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 15. 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. 16. 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 £t MAINTENANCE REQUIREMENTS 17. 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 Page 4 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Initial Testing Requirements 18. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.17) Periodic Testing Requirements 19. On an annual basis, the owner/operator must complete a site specific extended gas analysis ("Analysis") of the buffer house gas in order to verify the VOC content (weight fraction) of this emission stream. The buffer house gas sample must be comprised of all gas streams that collect in the buffer house. 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 "Notesto 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). ADDITIONAL REQUIREMENTS 20. All previous versions of this permit are cancelled upon issuance of this permit. 21. 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 V0C or N0X per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or Page 5 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 22. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source must not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 23. 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 N.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 24. 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. 25. 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. 26. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. Page 6 of 10 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 27. 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 ob 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. 28. 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. 29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT James Ricci Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Crestone Peak Resources Operating, LLC for venting of low-pressure gas venting at the buffer house during VRU downtime at a synthetic minor facility in the non -attainment area. Page 7 of 10 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 Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to, inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) Buffer 012 Benzene 71432 795 40 Toluene 108883 492 25 Ethylbenzene 100414 43 2 Xylenes 1330207 242 12 n -Hexane 110543 5772 289 2,2,4-Trimethylpentane 540841 2 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. Page 8 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors (lb/MM scf) Controlled Emission Factors (lb/MM scf) Source -- NOx 1.46 x 102 1.46 x 102 AP -42 -- CO 6.64 x 102 6.64 x 102 -- VOC 6.80 x 104 3.40 x 103 Buffer house extended gas analysis sampled on 12/19/2018 at 29 psig and 60 deg F 71432 Benzene 1.35 x 102 6.75 x 10° 108883 Toluene 8.36 x 101 4.18 x 10° 100414 Ethylbenzene 7.31 x 10° 3.65 x 10-1 1330207 Xylene 4.11 x 10' 2.06 x 10° 110543 n -Hexane ; - 9.81 x 102 4.90 x 101 540841 2,2,4-Trimethylpentane 3.96 x 10-1 1.98 x 10-2 Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The emission factors listed above are based on a buffer house temperature of 60°F and pressure of 28 psig. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Not' ice associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN ' expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU Page 9 of 10 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package 4: Received Date: Review Start Date: Section 01- Facility Information Company Name: C County AIRS ID: 12.. Plant AIRS ID: .3815 Facility Name: Ruegge4H-N165Battery Location: urces Operating, LLC SESW Quadrant of Section 4, Township 1N, Range 65W County: Weld County Type of Facility: .Expleratlen&PrddtiptionWell Pad: What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ❑ Carbon Monoxide (Co) ❑. Section 02 - Emissions Units In Permit Application Quadrant Section Township Range 4 N 65. ;. Particulate Matter (PM) p ozone (NOx & VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit# Issuance # Self Cert Required? Action Engineering Remarks 001 dense Tank " TANKS':Yes GP01= 2 Ncr-perrniti. Modification Package 391741 002 Produced Water Tank -- PW - Yes - 19WE0028.CP1 ---1 .:- Yes Permltlnit€al €ssuanc :: 003 Liquid Loading L0AD-1 Yes 13WE1392.CP2 2 y permit Modificaticttt 012 ....[ssuance - -Separator Venting - Buffer --- Yes --19W E0052-CP1 1 - yam Permit Initial Section 03 - Description of Project Crestone Peak Resources Operating, LLC (Crestone) currently owns and operates the Stelling Battery. Crestone has requested a name change for this facility, from "Stelling Battery" to "Ruegge 4H-NIS5i.Battery" as well as modifications to the currently permitted sources at the facili₹y. The existing Stelling facility consisted of seven wells, fve of the wells have been plugged and ' abandoned. The remaining two wells flow to the newly constructed facility along with eighteen newly wells that came online October 2018. The exi Sing buttery and all associated equipment were removed, and a new facility was constructed in its same location. The twenty (20) wells on site each produce through high/low pressure separators followed by a.bulk separator. Hydrocarbon liquids from the bulk separator are routed through a vapor recover tower (VRT) before being sent to the ,condensate storage tanks Produced water from the high/low pressure separators Is routed directly to,water storage tanks. Gas from the low- pressure separators are routed to. VRUs. In the event the VRUs are offline, gas is sent to enclosed combustors for control, Storage tank emissions are routed to enclosed flares for control. Gas from the high-pressure separators and VRT is directed to the sales line via VRUs. Produced water is transported from the facility via truck. Condensate is transferred out of the facility either by pipeline or truck. - --- -- - - Additionaly, the facility operates eight enginesthat have a site rated -horsepower -of less than 50 hp and are categorically exempt from permitting per Colorado Regulation 3, Part 8, Se It.D.1,c.(iii(. The facility has two additional engines covered unver GP02s. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Minor Permit Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No ' If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes 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 (P5D) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) 502 ❑ Y NOx CO VOC PM2.5 PM10 TSP HAPs DO ❑ ❑ ❑ O O ❑ ❑ ❑ Li SO2 NOx CO VOC PM2.5 PM10 TSP HAPs OOOOO ❑ ❑ ❑ OOO CICIO ❑ ❑ Separator Venting Emissions Inventory 012 Separator Venting Facility AIRs ID: 123 County 3815 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Limited Process Parameter Gas meter Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Separator Actual Throughput= Requested Permit Limit Throughput =, Potential to. Emit (PTE) Throughput = Mscf per year MMscf per year MMscf per year Requested Monthly Throughput= MMscf per month Process Control (Recycling) Equipped with a VRU: Is VRU process equipment: ',controlled and controlled emissions used to establish requested permit limits are based only on when the VRU is bypassed (i.e. waste gas volume that is routed to the. flare) Secondary Emissions- Combustion Device(s) for Air Pollution Control Separator Gas Heating Value: Volume of waste gas emitted per BBL of liquids throughput: Section 04 - Emissions Factors & Methodologies Description MW Btu/scf scf/bbl From ProMax :s was taken frem the bu€fer house on 12/19/2000 at 28. as g and 60 dog r An e ≤e 37;50 Weight % 02, Argon 0.1i CO2 .1.94 N2 0.0A methane 12.32. ethane 15.95 propane 30.23'. isobutane 6.51 n -butane 17:85: isopentane 4.43 n -pentane 4.09 cyclopentane 0,28. n -Hexane 0.99'. cyclohexane 0.24 Other hexanes 1.74 heptanes 0 46 methylcyclohexane 0.19 224-TMP 0,00 Benzene 0. 14 Toluene 0.08 Ethylbenzene 0.00 Xylenes 0 04 C8 0.24 C9 0 09 C10 0.23: Total VOC Wt % 100.00 58.60 Ib/Ib-mol Displacement Equation Ex= Q. MW `Xx/C Pollutant Separator Venting Uncontrolled (lb/MMscf) Controlled (lb/MMscf) 6.90E:+34 IEMEM Emission Factor Source Pollutant 3.96E-01 2.06E -N30 1.98E-02 Primary Control Device Uncontrolled (Ib/MMBtu) (Waste Heat Combusted) Uncontrolled lb/MMscf .0075'. :0580 x.__m (Gas Throughput) Emission Factor Source lb/Mscf Engineer Cad Applicant Cale 67960.42627 67957.86612 0.0% 135.0500026 135.0662589 0.0% 83.60238259 83.58817533. 0.0% 7.222454354 7.305470608 1.1% 41.15809604 41.114509 -0.1% 980.6707884 980.6320082 0.0% 0.395750923 0.39585457 0.0% 2 of 5 K:\PA\2019\19WE0052.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 Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM2.5 son NOx VOC CO 0.05 0.05 0.05 0.0 0.0 0 0.05 0.05 0.05 0.0 0.0 8 out 0.00 too 0.0 0.0 1 0.43 0.4.3 0,43 0,4 0.4 7.3 200,00 200.00 10,00 20(1,0 10.0 .1699 1.95 5.95 1.95 2.0 2.0 332 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ihs/year) Requested Permit Limits Uncontrolled Controlled lbs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224TMP 795 795 40 795 40 492 492 25 492 25 43 43 2 43 2 242 242 12 242 12 5772 5772 289 5772 289 2 2 0 2 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.B, G Regulation 7, Section XVII.B.2"e (See regulatory applicability worksheet for detailed analysis) Source requires a permit Source is subject to Regulation 7, Section XVII.B.2, G The control device for this separator is not subject to Regulation 7, Section XVII.B.2.e Section 07 - Initial and Periodic Sampling and Testing Requirements Using Gas Throughput to Monitor Compliance Does the company use site specific emission factprs based on a gas sample to estimate emissions? This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application. Are facility -wide permitted emissions of VOC greaterthan 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? Nis If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bhl) 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 3 015 K:\PA\2019\19WE0052.CP1 Separator Venting Emissions Inventory Section 08 - Technical Analysis Notes Thee buffer. h oenpr of gasfram th seturaxor the heater treater andthe VRT. Oufrng5"t, be required to ensure the em -s onfact s �emarr rep esentative ofth sfanlity Th r re siigh Section 09 - Inventor, 5CC Coding and Emissions Factors AIRS Point!! 012 Process 0 SCC Code 01 3-10-001-60 Flares Uncontrolled Emissions Pollutant PM10 PM2.5 S0x N0x V0C CO Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP Factor 15.97 15.97 1.26 345.71 6'.1'957.07 054.20 135.07 83.59 7.31 41.11 980.53 0.40 Control % Units 0 Its/MMSCF 0 ib/MMSCF 0 lb/MMSCF 0 b/MMSCF 95 Ib/MMSCF 0Ib/Mt5l6CF 95 16JMMSCF 95 Ib/MMSCF 95 Ib/MMSCF 95 Ib/MMSCF 9.5 lb/MMSCF 95 Ib/MMSCF 4 of 5 K:\PA\2019\19 W E0052.CP1 Separator Venting Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements Pearce ism the Nan.Attainmont Area ATTAINMENT S. Are uncontrolled actual emissions horn any criteria pollutants from this Individual source greater than 2 TP1 (Regulation 3, Part A, Section 11.0.1.0)? 2. Are total facility uncontrolled VOC emissions greater than 5TPY, NOn greater than 10TPY or CO emissions greater than SOTPY (Regulation3, Part B, Section 11.0.3(7 (Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than)TPY (Regulation3, Part A, Section 11.0.1.a)? 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY, NO0 greaterthan 5 TPY or CO emissions greater than 1OTPY (Regulation 3, Part B, Section 11.0.2)? ISaurce moue.. a permit Colorado Regulation 7. Section XVII 1. Was the Well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014? (Source is suAiezn to Regulation 7, Sa0n'on XVI1.0.5 G Section XVII.B,2—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.5 - Emissions Control Alternative Emissions Control (Optional Section) a. Is this separator controlled by a back-up or alternate combustion device (I.e., not the primary control device) that is not enclosed? (The control device for this separator is not subject to Regulation 7, Section XVii.U:i.e Section XVII.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act. its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysts A 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 Afr 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 teens of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legal, binding requirements in and of itself ource Req ource Req [ .YrSource rs sl. WAWThe control hE" see ak-ktut-4- Pod rece;��d lo Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN) and Application for Construction Permit DEG 2B All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /°7W 0)025 AIRS ID Number: 123 13815 D d2 - [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: pcs_ (viJtq ( £%ti C -CL" eiNk Crestone Peak Resources Operating, LLC Ruegge 4H -N165 Battery . SE5W Ser 44 TIN RI,CAAJ Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.weiner@crestonepr.com 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. 3q/7q3 Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 Ailk,COLORADO 1 I H6ntv4onpi Permit Number: AIRS ID Number: 123 /3815 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source 0 Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR MODIFICATION to existing permit (check each box below that applies) O Change in equipment ❑ Change company name3 o 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 - APEN submittal for permit exempt/grandfathered source O Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment Identification No. (optional): For existing sources, operation began on: Produced Water Storage Tanks PW ✓ 11/04/2012 ✓ For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week ✓❑ Exploration & Production (E&P) site 52 weeks/year 0 Midstream or Downstream (non EEtP) site Will this equipment be operated in any NAAQS nonattainment area? ✓ Yes ❑ No Are Flash Emissions anticipated from these storage tanks? Er Yes F No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? ❑ Yes No ✓ Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes ✓ No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ❑ Yes No ✓ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? ❑ Yes No ✓ Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 tO LO R ADO N„=Uvnnw,,, Permit Number: AIRS ID Number: 123 / 3815 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Produced Water Throughput: 985,500 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 1,000 10/2018 10/2018 Wells Serviced by this Storage Tank or Tank Battery6 (E£tP Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 34764 Stelling 3A -4H ❑ 05 - 123 - 35413 Stelling 3B -4H ❑ 05 -123 -46569 Ruegge 3C -4H -N165 ✓ 05 -123 -46556 Ruegge 3D -4H -N165 O 05 -123 -46565 Ruegge 3E -4H -N165 ✓ 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.07528 / -104.67053 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp, (°Fl Flow Rate (ACFM) Velocity (ft/sec) PW Indicate the direction of the stack outlet: (check one) ❑ Upward 0 Downward El Horizontal ['Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ['Square/rectangle Interior stack width (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 CO COR ADO 3 �, I Ai.u. ....,,, Permit Number: AIRS ID Number: 123 /3815/ [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. Vapor 0 Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Btu /scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: 0 Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 - Gas/Liquids Separation Technology Information (EBtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 30 psig Describe the separation process between the well and the storage tanks: Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2018 pp COLORADO 4I.Nea iahbm�:.P kt Permit Number: AIRS ID Number: 123 /3815/ [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 verall (or combined) control efficiency (% reduction ): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (%reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Criteria Pollutant Emissions Inventory Pollutant Emission Factor y Actual Annual Emissions , Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Ye ) Controlled E missions$ (tons/year) Uncontrolled Emissions tons/ ear (tons/year) ) Controlled Emissions (tons/year) !� ) VOC 0.066 lb/bbl Flash Liberation 32.44 ✓ 1.62 ✓ N0x 0.068 Ib/MMBtu AP -42 -- 0.06 CO 0.31 lb/MMBtu AP -42 -- 0.26 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (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 0.0003 ✓ lb/bbl Flash Liberation 313 ✓ 16 ✓ Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.0037 ✓ lb/bbl Flash Liberation 3674 f 184 sr- 2,2,4 - Trimethylpentane 540841 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 co LO 9 ADO 5 1 A a, '. M��h k Anr�ror , fns Permit Number: AIRS ID Number: 123 /3815/ [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. 12/26/2018 Signature of egally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance 0✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B 1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 7/2018 6 A�COLORADO 'Rofbtir E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Crestone Peak Resources Operating, LLC Source Name: Ruegge 4H -N165 Emissions Source AIRS ID2: 123 / 3815 / TBD Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 46570 Ruegge 3F -4H -N165 /Z/ 05 -123 - 46566 Ruegge 3G -4H -N165 /r1 05 -123 - 46558 Ruegge 311 -4H -N165 /1 05 -123 - 46559 Ruegge 3I -4H -N165 ►/ 05 -123 - 46562 Ruegge 3J -4H -N165 // 05 -123 - 46563 Ruegge 3K -4H -N165 // 05 -123 - 46561 Ruegge 3L -4H -N165 /t 05 -123 - 46567 Ruegge 3M -4H -N165 ►�I 05 -123 - 46571 Ruegge 3N -4H -N165 // 05 - 123 - 46564 Ruegge 3O -4H -N165 // 05 -123 - 46557 Ruegge 3P -4H -N165 // 05 - 123 - 46560 Ruegge 3Q -4H -N165 ./ 05 - 123 - 46568 Ruegge 3R -4H -N165 /1 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 4bi - APEN - Wellsite Addendum (PW).docx Qcety 1,O'10111 Produced Water Storage Tank(s) APEN - Form APCD-207 Air Pollutant Emission Notice (APEN).and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store produced water associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, condensate storage tanks, hydrocarbon liquid loading, etc.). in addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacifictcdphe/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: AIRS ID OO1-1 Number: 123 /3815 / 0 02 [Leave blank unless APCD has already assigned a permit # and AIRS ID) Section 1 - Administrative information Company Namer:. firestone Peak Resources Operating, LLC Site Name: Ruegge 4H -N165 Battery Site Location Site Location: SESW, Sec 4, T1 N, R65W County: Weld Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 NAICS or SIC Code: 1311 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E Mail Address2: taryn.weiner©crestonepr.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits,: exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 712013 COLORADO I tery ;nY.d FJ'Ic Permit Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source El Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP05 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. OR - • MODIFICATION to existing permit (check each box below that applies) O Change in equipment O Change company name3 o Change permit limit ❑ Transfer of ownership4 O Other (describe below) -OR- [� APEN submittal for update only (Note blank APENs will not be accepted) - ADDmONAL PERMIT AcnoNs ❑ APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional info a Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Company equipment identification No. (optional): Produced Water Storage Tanks PW For existing sources, operation began on: 11/04/2012 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 ✓❑ Exploration E Production (ESP) site weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? IJ Yes ■ No Are Flash Emissions anticipated from these storage tanks? jg _Yes No Are these storage tanks located at a commercial facility that accepts oil production wastewater for processing? Yes No 4 Do these storage tanks contain less than 1% by volume crude oil on an annual average basis? ❑ Yes p No Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)• 805 series rules? If so, submit Form APCD-105. Yes No p Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual• emissions a 6 ton/yr (per storage tank)? Yes No © Form APCD-20T- Produced Water Storage Tank(s) APB,' - Revision 7/2018 RADO 2 I{oIO �;�', Nm4k_ n Permit Number: AIRS ID Number: _9 23 - /3815/ [Leave blank unless APCD has already assigned a permit N and AIRS ID) Section 4 - Storage Tank(s) Information Produced Water Throughput: Actual Annual Amount (bbttyeorj .. Requested Annual: Permit Limit (bblfyeor) "" 985,500 From what year is the actual annual amount? Tank design: Fixed roof N/A O Internal floating roof O External floating roof Storage " Tank ID # of Liquid Manifold Sfor age ! Vessels in Storage Tank ` Total volume of St -rage Tank fbbl) ! ' Installation Date of Most Recent Storage Vessel in : Storage Tank (monthlyear) Date of First : Production montfil year)" PW 2 1,000 10/2018 10/2018 Wells Serviced by this Storage Tank or Tank Battery E&P. Sites Only} APiNumber;_ lame of `Nell'. Newly. Reported -Well 05 -123 -34764 Stelling 3A -4H 05 -123 -35413 Stelling 3B -4H 05 -123 -46669 Ruegge 3C -4H -N165 /❑ 05 -123 -46556 Ruegge 3D -4H -N165 05 -123 -46565 Ruegge 3E -4H -N165 Requested values will become permit limitations. Requested limit(s) should consider future growth, 6 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all welts that arc serviced by the equipment reported on this ADEN form. Section 5 - Stack Information Geographical: Coordinates (Latitudeftongitade or UTM) 40.07528 / -104.67053 0P Stack O ratorID Discharge Height Above Ground Level (feet), . T em Flow Rate _ ` Velocity PIN Indicate the direction of the stack outlet: (check one) Q Upward ❑ Downward ❑Horizontal 0Other (describe): Indicate the stack opening and size: (check one) QCircular , interior stack diameter (inches): O Square/rectangle interior stack width (inches): Ei Other (describe): O Upward with obstructing raincap Interior stack depth (inches): Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2013 CV ORADO 3 i° oft :04.10.".:. Permit Number: AIRS ID Number: 123 13815 [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. Vapor El Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: Combustion Device: Pollutants Controlled: vOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: Q Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr --- Q Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? psig Describe the separation process between the well and the storage tanks: to wR ADO ,Form APCD-207 - Produced Water Storage Tanks) ,OPEN - Revision 7/20?B VOC Permit Number: AIRS ID Number: 123 /3815/ (Leave blank unless APCD has already assigned a permit # and MRS IDI Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form7. If multiple emission control methods were identified in Section 6, the following table can be used to state the __ overall (or combined) control- efficiency (% reduction): on of Control`Method(s) Overall Requested Control Efficiency •• 0; reduction in emissions) Enclosed Combustor 95% NOx CO HAPs E,dosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Pollutant;. VOC Criteria Pollutant Emissions Inventory mission Factor? Uncontrolled Basis " Ib/bbl _rce AP; 42, Actual Annual Emissions Uncontrolled. Emissions ,. (tonstyear). Controlled Emissions$ (tons/year) Requested Annual Permit" Emission Limit(s)5 Uncontrolled Emissions (tons/year) Controlled;, - 'Emissions Emissions (tons/year) 0.262 CDPHE 129.10 6.46 NOx 0.068 lb/MMBtu AP -42 0.23 CO 0.31 lb/MMBtu AP -42 1.03 Toluene 108883 Benzene on -Criteria Reportable Pollutant Emissions inventory Chemical Abstract Service (CAS) Number..... 71432 mission Factor? Uncontrolled Basis 0.007 Units- lb/bbl ,ource,. - (AP 42 Mfg., etc.) Flash Liberation Actuafi Annual'. lncontrotted Emiss o s (Pounds/year) .. 6899 Emission.'s Controlled £missions$ {poundslyear) 345 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 0.022 lb/bbi Flash Liberation 21681 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 emissionsfactors according to the guidance in PS Memo 14-03, a Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-207 - Produced Water Storage Tank(s) APEN - Revision 7/2013 • 1084 [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. • �.� 10/10/2019 Signature of Dally 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:. Q Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result In an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C, for revised APEN requirements. Send this form along with $191.13 and the General Permit registration fee of $312.50, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make Bieck 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.colorado4ovicdohe/apcd roan APCD-207 - Produced Water Storage Tank(s) APEN Revision 7/2018 AV p c010RaII0 6 I Al Jam, t. E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: Crestone Peak Resources Operating, LLC Source Name: Ruegge 4H -N165 Emissions Source AIRS ID2: 123 / 3815 / TBD Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well _- 05 -123 - 46570 Ruegge 3F -411-N165 )1,I 05 -123 - 46566 Ruegge 3G -4H -N165 el 05 -123 - 46558 Ruegge 3H -4H -N165 ti 05 -123 - 46559 Ruegge 3I -4H -N165 0 05 -123 - 46562 Ruegge 3J -4H -N165 . 05 -123 - 46563 Ruegge 3K -4H -N165 /1 05 -123 - 46561 Ruegge 3L -4H -N165 El 05 -123 - 46567 Ruegge 3M -4H -N165 ►1 05 -123 - 46571 Ruegge 3N -4H -N165 ►.1 05 -123 - 46564 Ruegge 3O -4H -N165 ►� 05 -123 - 46557 Ruegge 3P -411-N165 El 05 -123 - 46560 Ruegge 3Q -411-N165 /t 05 -123 - 46568 Ruegge 3R -4H -N165 al - - ❑ - - •. - _ El - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212. Obi - APEN - Wel]site Addendum (PW).docx Crestone Peak Resources Operating LLC Facility: Ruegge 4H -N165 Source ID: PW AIRS ID: TED Annual Throughput:. 985,500 ,bbl/yr -- — _ Control Method: ECD Control Efficiency: 95% Waste Gas: 53.04 lb/lb-mol 86.31 deg F 519.67 deg R 12.12 psia 2,980 Btu/scf Gas Constant: 10.73 scf-psia/lb-mol-deg R Flash Liberation Analysis - Produced Water Storage Emission Factor Calculations Gas Water Ratio 1.082 0 Gas Molar Volume @60 F, 14.7 psi 379 scf/mol Gas Molecular Weight 38.74 lb/lbmol VOC Content 59.52 wt % Benzene Content 0.29 wt % n -Hexane Content 3.37 wt % Flash Gas VOC Emission Factor: - -- 0.066 lb/bbl Flash Gas Benzene Emission Factor: 0.0003 i13/bbl Flash Gas n -Hexane Emission Factor: 0.0037 lb/bbl - .. _ ... -- - . _- Produced water Emission Factors Pollutant CDPHE - Factors VOC 0.262 lb/bbl Benzene 0.0070 lb/bbl n -hexane 0.0220 lb/bbl Combustion AP -42 Chapter 13.5 NOx 0.0.68 lb/MMBIu CO 031 lb/MMBtu Pollutant Uncontrolled Emissions . Controlled Emissions lb/yr ton/yr lb/yr ton/yr VOC 258201 129.10 12910 6.46 Benzene 6899 3.45 345 0.17 n -Hexane 21681 10.84 1084 0.54. NOx ' -- - 454 0.23 CO -- - 2069 1.03 Emission Factor Calculation: lb/bbl = Gas Water Ratio (scf/bbl) * 1 / Gas Molar Volume (1 / scf/Ib-mol) * Gas Molecular Weight (lb / lb-mol) * Componentwt%/ 100 11/6/2019 State.co.us Executive Branch Mail - APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 Taryn Weiner <taryn.weiner@crestonepr.com> Tue, May 28, 2019 at 4:46 PM To: "Ricci - CDPHE, James" <james.ricci@state.co.us> I wanted to check in. We had an outside contractor work on the Promax model, so they are working on responding to these questions and I will get them to you as soon as possible. As for the non-Promax related questions, my responses are in red below. Thank you Taryn Weiner Air Quality Supervisor Crestone Peak Resources 10188 East 1-25 Frontage Road, Firestone, CO 80504 T: 303-774-3908 C: 720-360-9226 E:taryn.weiner@crestonepr.com CRESTONE PEAK RESOURCES Please note Crestone Peak Resources is closed the 1st and 3rd Friday of each month. From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Monday, May 20, 2019 2:43 PM To: Taryn Weiner <taryn.weiner@crestonepr.com> Subject: [EXT]Re: APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 Hi Taryn, just wanted to check in to see if you have a chance to review these questions. No problem if you need more time! Thanks, James Ricci Permit Engineer httos://mail.aooale.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1634817637302456598&simpl=msg-f%3A16348176373... 1/2 11/6/2019 State.co.us Executive Branch Mail -APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 CDPHE COLORADO Air Pollution Control Division Department of Public Health B Env,ronment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd On Thu, Apr 25, 2019 at 9:08 AM Ricci - CDPHE, James <james.ricci@state.co.us> wrote: Good Morning Taryn, I am reviewing the APENs submitted for the Ruegge 4H -N165 Battery, AIRS ID 123-3815-002, I am hoping you can help me with the questions below: Condensate Tanks Contractor working on • Can you please send me the entire ProMax report? I'm mainly look for the W&B Stencil inputs and the lb/h for each stream but the entire report would be good too. • Sales Oil is set at 131.184 sgpm = 1,641,674 bbl/year, this is a bit higher than the requested throughput on the APEN. • Is the pressurized liquid sample taken at the facility equivalent to Sep Oil or Stream 47 in the ProMox model? I'm confused since the sample was taken at 52 psig but pressure is being dropped to 35 psig at Stream 2. • Regardless of the answer above, is making a pseudo wellhead stream the most accurate way to model this process? What happens to the emission factors if we input the pressurized liquid sample directly where it was taken and ignore everything upstream of it? I don't know enough about ProMax to tell you your method isn't accurate, please let me know if your approach is better than inputting the saturated sample directly into the model where it was taken Water Tanks • Can you please send me the produced water Flashed Gas Extended Analysis? Attached • Section 3: "Are Flash Emissions anticipated from these storage tanks?" - I think this answer should be "yes," please let me know if you agree and if I can redline the APEN. Yes I agree • O&M Plan - It is noted that these tanks are not subject to Reg 7 XVII.C.2/3. Since uncontrolled emissions are greater that 6 tpy/tank, I think these tanks should be subject. Is there a different reason why you don't think these tanks should be subject? You are correct, these are subject to this, that was incorrect Loadout Section 3: "Does this source splash fill less than 6750 bbls of condensate per year?" - I think this answer should be "yes" since 0 bbls will be splash filled, please let me know if you agree and if I can redline the APEN. Yes this was a typo, please redline • Do you have a sales oil analysis you can share? Is this where you pulled MW from? How are you estimating temperature? These were taken from the promax run • Are the HAP mass fractions from the sales oil analysis? Or from a different source? We used the condensate tank overheads stream for HAP mass fraction Venting Contractor working on [Quoted text hidden] Ruegge 4H -N165 Bulk Separator Pressurized Water FLA.pdf 147K httos://mail.aooa le.00m/mai I/u/0?i k=5517734b80&view=pt&search=a I I&perm msgid=msg-f%3A 1634817637302456598&si m pl=msg-f%3A16348176373... 2/2 (1.O3. 0\1 G kAQ, c .h S Op ER S E b E 6: re Lot to 20, Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 13WE1392 AIRS ID Number: 123 / 3815 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name: Site Name: Site Location: Bcc_ I/zrf(i`f a,tia.cked el'464( Crestone Peak Resources Operating, LLC Ruegge 4H -N165 Battery 5 5fff Sec `/ Tik R6CW Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, CO 80504 Site Location County: Weld NAICS or SIC Code: 1311 Contact Person: Phone Number: E -Mail Address2: Taryn Weiner (303) 774-3908 taryn.weiner@crestonepr.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 :COLORADO 1IAV; k,a:�� a Enrtrvnmvn� Permit Number: 13WE1392 AIRS ID Number: 123 / 3815 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action D NEW permit OR newly -reported emission source ❑ Request coverage under construction permit ❑ Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑✓ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 ✓❑ Change permit limit O Transfer of ownership4 ❑ Other (describe below) OR - ▪ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ▪ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info 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 Ioadout of condensate from tanks Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: 11/04/2012 For new or reconstructed sources, the projected start-up date is: Will this equipment be operated in any NAAQS nonattainment area? Yes No is ■ Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No ■ f5I Is this source located at an oil and gas exploration and production site? Yes No • ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No O ■ Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No • is Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 ICO LO RADO 2 I _. Department 41Pailiic Permit Number: 13WE1392 AIRS ID Number: 123 /3815/003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: El Condensate O Crude Oil O Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1,449,050 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:Average 0.60 temperature of bulk liquid loading: Q c . 8V 31 ° F True Vapor Pressure: 6.60 Psia @ 60 ° F Molecular weight of displaced vapors: �� • O A `+ lb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year Product Density: lb/ft3 Load Line Volume: ft3/truckload • Vapor Recovery Line Volume: ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 - Hydrocarbon Liquid Loading APEN Revision 7/2018 �ji 'COLORADO Permit Number: 13WE1392 AIRS ID Number: 123 / 3815/003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.07528 / -104.67053 "x Operatorz Stack ID No Discharge Height Above Ground Level e.r; (feet) x Temp (*� Flow Rate C (ACFM) Veroci fft/ LOAD -1 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) ❑ Circular O Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: ❑ Combustion Device: Used for control of: VOCs, HAPs Rating: Type: Enclosed Combustor MMBtu/hr Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 % Minimum Temperature: °F Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 4 I • HtMrhk%minmm# Permit Number: 13WE1392 AIRS ID Number: 123 / 3815 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner 12/26/2018 Air Quality Engineer Name (print) Title Check the appropriate box to request a copy of the: O 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.Rov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 a COLORADO 6I�. Permit Number: 13WE1392 AIRS ID Number: 123 / 3815 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM SOX 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 Limit(s)5 Uncontrolled Basis Units Source. (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SOX NO. 0.068 lb/MMBtu AP -42 -- 0.27 CO 0.31 Ib/MMBtu AP -42 — 1.23 VOC 0.201 lb/bbl AP -42 145.77 7.29 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service CAS (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions6 (pounds/year) Benzene 71432 3.95e-04 lb/bbl Eng. Est. 573 29 Toluene 108883 3.03e-04 lb/bbl Eng. Est. 439 22 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 2.23e-03 lb/bbl Eng. Est. 3236 162 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN Revision 7/2018 5 I AV';;COLORADO MA* trEM•ln•Rr ;4= Reie100ta J2o►`-‘ Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit ALL sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined Incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of ail available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdohe/ancd. 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, ILC. for revised APEN requirements. Permit Number. 13WE1392 AIRS ID Number, 123 / 3815 / 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': Creston Peak Resources Operating, LLC Site Name: Ruegge 4H -N165 Battery Site Location Site Location: - SESW,_SeCR65W county --Weld Mailing Address: (Include Zip Code) 10188 East 1-25 Frontage Road NAICS or SIC Code: 1311 Firestone, CO 80504 Contact Person: Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.wefner@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. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 1 I AV COLORADO .r s� HPsan�sM Permit Number. 13WE1392 AIRS ID Number: 123 ' 38157 003 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action Cl NEW permit OR. newly -reported emission source O Request coverage under construction permit O Request coverage under General Permit GP07 If General -Permit coverage is request d, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- Q MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 El Change permit limit ❑ Transfer of ownership4 0 Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info 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 loadout of condensate from tanks Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: 11/04/2012 For new or reconstructed sources, the projected start-up date is: Wilt this equipment be operated in any NAAQS nonattainment area? Q Yes ■ No Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes CI No II Does this source load gasoline into transport vehicles? Yes No ■ p Is this source located at an oil and gas exploration and production site? Yes No 12 ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No © ■ Does this source splash fill less than 6750 bbl of condensate per year? Er Yes No Does this source submerge felt less than 16308 bbl of condensate per year? Yes No ■ p Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 2I 'COLORADO Y�rennw.�� Permit Number: 13WE1392 AIRS ID Number: 123 13815/003 [Leave blank unless APLD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: J Condensate Q Crude Oil [] Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1,449,050 bbltyear 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: Average temperature of bulk liquid loading: F True Vapor Pressure: Psia @ 60 `F Molecular weight of displaced vapors: tb/lb-mot If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: 5 Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year - Product Density: - -- tb/ft3 . _ ... ._ .._. Load Line Volume: ft3/truckload - Vapor Recovery Line Volume: ft3/truckload Requested values will become permit limitations. Requested limit(s)-should consider future -process growth. _ Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 coioi AA0 3 I .8,Y': Permit Number: 13WE1392 AIRS iD Number: 123 / 3815 / 003 eave blank unless APCD has aiready.assigned a permit it and AIRS ID] Section 5 - Stack Information Geographical Coordinates (i.ntitude/£angitude or. tlThfj 40.07528 / -104.67053 Ctpereror '3SGher sleight ,.. Gii]ISiki i_evel �. Teraip lti°l{ cdiie. .: LOAD -1 Indicate the direction of the stack outlet: (check one) ❑ Upward o Horizontal ❑ Downward O Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Other (describe): Interior stack diameter (inches): O Upward with obstructing raincap — -Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section, ❑ Loadino occurs using a vapor balance system:. _. . _... Requested Control Efficiency:.... rn Combustion Device: Used for control of: VOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: - 'F : Waste Gas Heat Content: Btu/scf Constant Pilot Light: ® Yes © No Pilot Burner Rating: . MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-208 -Hydrocarbon Liquid Loading APEN -Revision 7/2018 cc�osxaa 4 I s"x Benzene Permit Number: 13WE1392 AIRS ID Number: 123 /3815/003 [Leave Stank 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 overall (or combined) control efficiency (% reduction): be used to state the Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM sox NO. CO VOC Enclosed Combustor 95% HAPs Enclosed Combustor 95% Other: 13 Using State Emission Factors (Required for GPO]) El Condensate ❑ Crude VOC 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 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 Emission Factor Pollutant Uncontrolled Basis: - PM Ib/MMBtu Source ;m (AP-4Z• IS etc.) Actual Annual Emissions Uncontrolled Emissions (tons/year) Controlled Emissions¢ (tons/year] _• Requested Annual Permit _Emission;Limit(s)5. _......: Uncontrolled_ Emissions (tonslyear). Controlled Emissions (ty�') SOx NOx 0.068 AP -42 0.32 CO 0.31 lb/MMBtu AP -42 1.44 VOC 0.236 lb/bbl CDPHE 170.99 8.55 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Abstract Service'°(CAS) Number, 71432 Emission Factor. Actual Annual Emissions Uncontrolled Basis 4.16e-04 lb/bbl Source (AP -42 Mfg.; etc.) CDPHE Uncontrolled Emissions :`. . (pounds/year) " 603 Controlled ,• Emissionsb (pdunds/year) 30 Toluene 108883 Ethylbenzene 100414 Xylene 1330207 n -Hexane 110543 3.61e-03 lb/bbl CDPHE 5231 262 2, 2,4 Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. b. Annual emissions fees will be based on actual controlled emissions reported. if source has not yet started operating, leave blank. Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 LORADO 5 !�CO,-_�dP Permit Number:-13WE1392 AIRS ID Number: 123 / 3815 / O03 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that alt 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 wilt be operated in full compliance with each condition of General Permit GP07. Signature of /galty Authorized Person (not a vendor or consultant) Date 1,114-41-10/1` Taryn Weiner 10/10/2019 Air Quality Supervisor Name (print) Title Check the appropriate box to request a copy of the: El Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 COLORADO 6 I �rr — Creston PeakResources Operating=LC Fadiity; Ruegge 4H -N165 Sturm ID: LOAD -1 AIRS ID; 003 Equipment information Throughput Value fbbl/Yrl 1,449,050.00 Emission ContaIs: ECD 44 VOC Control 95% -- --—Tater-dialEmissions Combustion Source Waste Gas: 5104 )Ib/lh-mol 86.31 degF 145.90 deg R 1212 cola 2.980 Btalsd Gas Constant 10.73 sd osia/ibmoldeg R Pollutant VOC Loading Loss Through -PM • Uncontrolled Emissions Controlled Emissions [16/661) (bbl/yr) (Ib/Yr) (ipY) flb/Y() ftpY) 0236 1449055.00 341975.80 170,99 17098.79 8.55 CDPHE Source of Emission Factor 51APs Benzene Toluene Ethyibeemene 5gler-e n-Hooane 2.2,4 -TMP Loading Lass Throughput Uncontrolled Emissions Controlled Emissions Source of Emission Factor (lbfbbl) (bbl/,6r) (ibfyr) (toy) flb/sr) RFD 4.15E-04 - 1449050,00 603 230 30 0.02 CDPHE 0.00E+00 1449050.90 0 0.00 0 0.00 CDPIIE 0.00E+00 /44905000 0 0.00 0 0.00 CDPHE 0.00E+00 1449050.00 0 0.00 0 0.00 CDPHE 3.519x.-03 1.19050.00 5231 2_62 262 0.13 CDPHE 0,00E+00 1449050.00 0 0.00 0 0.00 CDPHE Combustion Emissions Pofomnt NOs CD Emission Factor Ih/MMAtu 0.058 0.31 Uncontrolled Emissions Controlled Emissions Source of Emission Factor (1967) - (rPy) flb/yr) [MY) 631.65 0.32 AP -12 287957 1.44 AP -42 11/6/2019 State.co.us Executive Branch Mail - APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 STATE OF COLORADO Ricci - CDPHE, James <james.ricci@state.co.us> APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 Taryn Weiner <taryn.weiner@crestonepr.com> To: "Ricci - CDPHE, James" <james.ricci@state.co.us> I wanted to check in. Tue, May 28, 2019 at 4:46 PM We had an outside contractor work on the Promax model, so they are working on responding to these questions and I will get them to you as soon as possible. As for the non-Promax related questions, my responses are in red below. Thank you Taryn Weiner - Air Quality Supervisor Crestone Peak Resources 10188 East I-25 Frontage Road, Firestone, CO 80504 T: 303-774-3908 C: 720-360-9226 E:taryn.weiner@crestonepr.com J� CRESTONE PEAK RESOURCES Please note Crestone Peak Resources is closed the 1st and 3rd Friday of each month. From: Ricci - CDPHE, James <james.ricci@state.co.us> Sent: Monday, May 20, 2019 2:43 PM To: Taryn Weiner <taryn.weiner@crestonepr.com> Subject: [EXT]Re: APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 Hi Taryn, just wanted to check in to see if you have a chance to review these questions. No problem if you need more time! Thanks, James Ricci Permit Engineer https://ma!I.google.com/mail/u/0?ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1634817637302456598&simpl=msg-f%3A16348176373... 1/2 11/6/2019 State.co.us Executive Branch Mail - APEN Review: Ruegge 4H -N165 Battery, AIRS ID 123-3815-002 ADPe • COLORADO Air Pollution Control Division Derailment of Public Health & Enororment P 303.691.4089 I F 303.782.0278 4300 Cherry Creek Drive South, Denver, CO 80246 james.ricci@state.co.us I www.colorado.gov/cdphe/apcd On Thu, Apr 25, 2019 at 9:08 AM Ricci - CDPHE, James <james.ricci@state.co.us> wrote: Good Morning Taryn, I am reviewing the APENs submitted for the Ruegge 4H -N165 Battery, AIRS ID 123-3815-002, I am hoping you can help me with the questions below: Condensate Tanks Contractor working on • Can you please send me the entire ProMax report? I'm mainly look for the W&B Stencil inputs and the lb/h for each stream but the entire report would be good too. • Sales Oil is set at 131.184 sgpm = 1,641,674 bbl/year, this is a bit higher than the requested throughput on the APEN. • Is the pressurized liquid sample taken at the facility equivalent to Sep Oil or Stream 47 in the ProMox model? I'm confused since the sample was taken at 52 psig but pressure is being dropped to 35 psig at Stream 2. • Regardless of the answer above, is making a pseudo wellhead stream the most accurate way to model this process? What happens to the emission factors if we input the pressurized liquid sample directly where it was taken and ignore everything upstream of it? I don't know enough about ProMax to tell you your method isn't accurate, please let me know if your approach is better than inputting the saturated sample directly into the model where it was taken Water Tanks Can you please send me the produced water Flashed Gas Extended Analysis? Attached Section 3: "Are Flash Emissions anticipated from these storage tanks?" - I think this answer should be "yes," please let me know if you agree and if I can redline the APEN. Yes I agree O&M Plan - It is noted that these tanks are not subject to Reg 7 XVII.C.2/3. Since uncontrolled emissions are greater that 6 tpy/tank, I think these tanks should be subject. Is there a different reason why you don't think these tanks should be subject? You are correct, these are subject to this, that was incorrect Loadout Section 3: "Does this source splash fill less than 6750 bbls of condensate per year?" - I think this answer should be "yes" since 0 bbls will be splash filled, please let me know if you agree and if I can redline the APEN. Yes this was a typo, please redline Do you have a sales oil analysis you can share? Is this where you pulled MW from? How are you estimating temperature? These were taken from the promax run Are the HAP mass fractions from the sales oil analysis? Or from a different source? We used the condensate tank overheads stream for HAP mass fraction Venting Contractor working on [Quoted text hidden] Ruegge 4H -N165 Bulk Separator Pressurized Water FLA.pdf 147K https://mai l.google.com/mail/u/0? ik=5517734b80&view=pt&search=all&permmsgid=msg-f%3A1634817637302456598&sim p I=msg-f%3A16348176373... 2/2 SWERgl-bE6 See �� cl.e� � P � ti ck,Ackenci.,0" ft. Le to I l° h �J1 �G232 Gas Venting APEN Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: AIRS ID Number: 123 /3815 / D 12 - [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: Site Location: gcc i �Lw ,l9 ?Qv- m-ttKNez( «.t,t.cu� Ruegge 4H -N165 Battery SESW Se :.L T(ti1 R6SNAJ Mailing Address: 10188 East 1-25 Frontage Road (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. Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 1I': MOW, Permit Number: AIRS ID Number: 123 /3815/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 O Add point to existing permit O Change permit limit ❑ Transfer of ownership' ❑ Other (describe below) OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info £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: low pressure separator venting to enclosed combustor when VRU's are offline Company equipment Identification No. (optional): For existing sources, operation began on: Buffer 10/02/2018 For new, modified, or reconstructed sources, the projected start-up date is: 0 Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: Will this equipment be operated in any NAAQS nonattainment area? hours/day Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, Section XVII.G? Form APCD-211 Gas Venting APEN - Revision 7/2018 days/week weeks/year Yes Yes Yes ❑ No ❑✓ No ❑ No 'COLORADO 2 I wn`P"'e<aot Public 11•01.AMlnMt�fMt Permit Number: AIRS ID Number: 123 /3815/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information ✓❑ Gas/Liquid Separator ❑ Well Head Casing O 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? Gas Venting Process Parameters5: Liquid Throughput Process Parameters5: Vented Gas Properties: ❑ Yes ❑✓ No Vent Gas Heating Value: 1,308.03 BTU/SCF Requested: MMSCF/year Actual: MMSCF/year -OR- Requested: 6419O bbl/year Actual: bbl/year Molecular Weight: 22.74 VOC (Weight %) 25.88 Benzene (Weight %) 0.05 Toluene (Weight %) O.O7 Ethylbenzene (Weight %) 0.02 Xylene (Weight %) 0.17 n -Hexane (Weight %) 0.34 2,2,4-Trimethylpentane (Weight %) 0.00 Additional Required Information: ❑✓ Attach a representative gas analysis (including BTEX ft n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX is n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-211 - Gas Venting APEN - Revision 7/2018 ,COLORADO 3 E7 Department of Public • 11.441,k Eml. vtmPm Permit Number: AIRS ID Number: 123 /3815/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.07528 / -104.67053 Operator Stack ib No Discharge Height Above Ground Level (Feet). Temp. Flow Rate (ACFM) Velocity (fUses.) Sep. Vent 20.0 Indicate the direction of the stack outlet: (check one) ❑� Upward O Horizontal 0 Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑✓ Circular 0 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: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed: % O Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: MMBtu/hr Other: Pollutants Controlled: Description: Requested Control Efficiency: Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 4 I y.n' Permit Number: AIRS ID Number: 123 /3815 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency (% reduction): Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) PM 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 Limi5 t(s) Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year), Controlled Emissions (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM SO. NOx 0.068 Ib/MMBtu AP -42 -- 0.57 CO 0.31 Ib/MMBtu AP -42 -- 2.60 VOC 15.5 lb/Mscf Eng. Est. 99.50 4.97 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 6 Emissions6 (pounds/year) Benzene 71432 0.03 Ib/Mscf Eng. Est. 359 18 Toluene 108883 0.04 Ib/Mscf Eng. Est. 564 28 Ethylbenzene 100414 Xylene 1330207 0.10 Ib/Mscf Eng. Est. 1,292 65 n -Hexane 110543 0.20 Ib/Mscf Eng. Est. 2,575 129 2,2,4- Trimethylpentane 540841 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 COLORADO 5 I ra `'.'asc.otr�atic HINN tEr,rdrvnmmct Permit Number: AIRS ID Number: 123 /3815/ [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. Person g y (not a vendor or consultant) Date Signature of a all Authorized Taryn Weiner Air Quality Engineer Name (please print) Title Check the appropriate box to request a copy of the: ✓❑ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.Qov/cdphe/apcd Form APCD-211 - Gas Venting APEN - Revision 7/2018 cO LORABO 6 ,7, of <, neon txm invn-+fl Gas Venting APEN - Form APCD--211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. if your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). in addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: l4i► O 4". AIRS ID Number: 123 /3815 / (1%1 [Leave blank unless APCD has already assigned a permit # end MRS ID] Section 1 - Administrative Information -Company Name': -Crestone Peak Resources Operating, LLC - Site Name:. Ruegge 4H -N 165 Battery - Site Location:,. SESW, Sec 4, T1 N, R65W Site Location - Weld County: Mating Address: (Include Zip Code) 10188 East 1-25 Frontage Road Firestone, -Co 80504 NAICS or SIC Code: 1311 Contact Person: -Taryn Weiner Phone Number: (303) 774-3908 E -Mail Address2: taryn.weiner@crestonepr.com i Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. Form APCD-211 -. Gas Venting APEN -'Revision 7/2018 AV !COLORADO AV 1 I tx [Leave blank unless APCD has already assigned a permit # and AIRS ID] AIRS 1D Number. 123 /3815/ Section 2 - Requested Action Q NEW permit OR newly -reported emission source -OR- • MODIFICATION to existing permit (check each box below that applies) O Change fuel or equipment 0 Change company name3 0 Add point to existing permit o Change permit limit 0 Transfer of ownership4 O Other {describe below) -OR O APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACnONs - ID Limit Hazardous Air Pollutants (NAPS) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3_- General Information____. General description of equipment and purpose: low pressure separator venting to enclosed combustor when VRUrs are offline Company equipment identification No. (optional): Buffer For existing sources, operation began on: 10/02/2018 For new, modified, or, reconstructed sources, the projected start-up date is: Q Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: - Normal Hours of Source hours/day days/week Operation: 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 XVILG? - Form APCD-211 .. Gas Venting APEN Revision 7/2018 El Yes O Yes 0 .Yes. weeks/year ❑ No ❑✓ No ❑ No LOLCR ADO I ,z,-Tr-v—, nuw [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information • Gas/Liquid Separator O Well Head Casing O Pneumatic Pump Make: Model: O Compressor Rod Packing Make: Model: • Blowdown Events # of Events/year: O 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? Gas Venting Process Parameters5: Liquid Throughput _-_ Process Parameters5: Vented Gas Properties: 0✓ Yes [] No Vent Gas Heating Value: 2142.79 BTU/SCE Requested: 5.89 MMSCF/year Actual: MMSCF/year .. -OR- -Requested: -- bbl/year - _- Actual: — - - _ bbl/year Molecular Weight: $7.60 VOC (Weight %) 68.69 Benzene (Weight %) 0.14 Toluene (Weight %) 0.08 Ethylbenzene (Weight %) 0.01 Xylene (Weight %) 0.04 n -Hexane (Weight %) 0.99 2,2,4-Trimethylpentane (Weight %) 0.00 Additional Required Information: 0 • Attach a representative gas analysis (including BTEX & n-l-lexane, temperature, and pressure) I Attach a representative pressurized extended liquids analysis (including BTEXa n -Hexane, temperature, and pressure) 5 Requested values will become permit limitations. Requested limtt(s) should consider future process growth. GOL0JRADO Form APCD-211 - Gas Venting APEN - Revision 7/2018 3 } . Permit Number. AIRS ID Number: 123 /3815/ [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information raphical. Coordinates tudeiiarigffude or UTM).; 40.07528 / -104.67053 ,_#x..�..r� � erratnr ^��... . �. as p . � c ...W :..:..m, —r s. qq�� s; l�lx FT�+�` a ,�'"-s .,.�.. ..:.�..:�...: ��":..,,::'.a��:�:.�T UY °, Ground:.E.( ,.x st's`" .^ ,2'�'� ; }x ,#� •.a.ME. , �s s'�._ tea.,' r ^ 3��L ₹�'"�_ ..:....: �. ..,..: .. .:%,.... e..« .,,... .i`i �.. ......... „...,. ... �+i T?'��:.... �-e: ,� T:�Ri �a �..+Engsv+.m.�. n.: •::v '<.. -' ' `.:. .:�r ... '$i:.� ''% �. . Sep. Vent 20.0 Indicate the direction of the stack outlet: (check one) 0 Upward O Horizontal O Downward Other (describe): Indicate the stack opening and size: (check one) Circular O Other (describe): Interior stack diameter (inches): Upward with obstructing raincap 48 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, - - - . VRU: -- . Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed: a Combustion Device: Pollutants Controlled: VOCs, HAPs Rating: ' - MMBtu/hr Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: Q Yes No Pilot burner. Rating: Btu /scf MMBtu/hr .. Other: Pollutants Controlled: Description: Requested Control Efficiency: . Form APO -211 - Gas Venting APEN - Revision 7/2012 A!', CO .OR ADO 4 =IT c t11yc W,Jai->_nu��or_�>nt C emtcal Name Permit Number: AIRS ID Number: 123 / 3815 / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall (or combined) control efficiency {%reduction): Pollutant PM Description of Control Methoci(s) Overall Requested Control Efficiency "(% reduction in emissions) SOx NOx CO VOC Enclosed Combustor - 95% HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? N/A Pollutant --- PM Criteria Pollutant Emissions Inventory 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 (tons/year). Uncontrolled Emissions (tons//year) ... Controlled Emissions ,(tans/year).: SOx NO. 0.068 lb/MMBtu AP -42 0.43 -;=CO -- . — 0.31.--..-- Ib/MMBtu AP -42 ---- ----1.95 --- VOC 68 . ib/Mscf Eng. Est. 200.00 10.00 Non -Criteria Reportable Pollutant Emissions Inventory .~ Chemical Abstract , .. . Service (CAS) Number _ Emission Factor: Uncontrolled -. Basis - lb/Msef Actual Annual Emissions Source Uncontrolled - Emissions " (pounds/year) Controlled iEmission56 - !Pounds/year) Benzene 71432 0.14 Eng. Est. 795 40 Toluene 108883 0.08 lb/Mscf Eng. Est. 492 25 Ethylbenzene 100414 Xylene 1330207 0.04 lb/Nisei Eng. Est. 242 12 n -Hexane 110543 0.98 lb/Nisei Eng. Est. 5772 289 2,2,4- Trimethylpentane 540841 Other: Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees wilt be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-211 - Gas Venting APEN - Revision 7/2018 (Leave blank unless APCD has already assigned a permit Ii and AIRS ID] AIRS ID Number: 123 /3815/ Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. 10/10/2019 Signature o14Legally Authorized Person (not a vendor or consultant) Date Taryn Weiner Air Quality Supervisor Name (please print) Tithe Check the appropriate box to request a copy of the: Draft permit prior to issuance Q Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, iI.C. for revised APEN requirements. Send this form along with $191.13 to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303)692-3150 Or visit the APCD website at: httos://www.colorado.gov/cdphe/aoccl COLCRACO Form APCD-2I1 = Gas Venting APEN - Revision 7/2018 Hello