HomeMy WebLinkAbout20192109.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
May 29, 2019
Dear Sir or Madam:
RECEIVED
JUN 04 20T
WELD COUNTY
COMMISSIONERS
On June 6, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
HighPoint Operating Corportaion - Critter Creek 24-1 Production Facility . A copy of this public notice
and the public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor
c1.) C c e) -e
C p11'Z 11a
I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
CC%PLeTP),NL(JT)�
PW(4t-A isR Ic ticiA)
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2019-2109
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: HighPoint Operating Corportaion - Critter Creek 24-1 Production Facility - Weld
County
Notice Period Begins: June 6, 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:
Facility:
HighPoint Operating Corportaion
Critter Creek 24-1 Production Facility
EEtP Well Pad
NWNE Quadrant of Section 24, Township 11N, Range 63W
Weld County
The proposed project or activity is as follows: HighPoint Operating Corportaion intends to permit crude
storage and crude loadout at a multi -well facility located in the attainment area.
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 18WE0905.CP1 have
been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
James Ricci
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
1 �_ .,.
N.aNA66nvi.[wiM.nY.
th & Environment
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0905 Issuance: 1
)000(
HighPoint Operating Corporation
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Critter Creek 24-1 Production Facility
123/9FCA
NWNE Quadrant of Section 24, Township 11N, Range 63W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Crude TKs
003
Ten (10) 840 barrel fixed roof storage
vessels used to store crude oil
Enclosed Combustors
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, bar
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the
permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, compliance with the conditions contained in this permit shall
be demonstrated to the Division. It is the owner or operator's responsibility to self -
certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. A self certification form and guidance on
COLORADO
Air Pollution Control Division
Department of PubLe Heaitn Er Dmronment
Page 1 of 9
rtify pli. as uired by this permit may be obtained online at
.>7o he/r- ermi self -certification. (Regulation Number 3, Part B,
nIG )
3. s pe s pi •wne • operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the
date on which such construction or activity was scheduled to commence as set forth in
the permit application associated with this permit; (ii) discontinues construction for a
period of eighteen months or more; (iii) does not complete construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in
this permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
Crude TKs
003
--
1.9
50.4
8.9
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0
tons per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all
permitted emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall
be determined on a rolling twelve (12) month total. By the end of each month a new
twelve month total is calculated based on the previous twelve months' data. The permit
holder shall calculate actual emissions each month and keep a compliance record on
site or at a local field office with site responsibility for Division review.
7. The emission points in the table below shall be operated and maintained with the
emissions control equipment as listed in order to reduce emissions to less than or equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
CDPHE
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Page 2 of 9
E i • : t
of
Control Device
Pollutants
Controlled
Crude TKs
003
Enclosed Combustors
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Crude TKs
003
Crude Oil
Throughput
1,500,512
barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve-month total is calculated
based on the previous twelve months' data. The permit holder shall calculate
throughput each month and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g.
123/4567/001) shall be marked on the subject equipment for ease of identification.
(Regulation Number 3, Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7,
Section XVII.B.2. General Provisions (State only enforceable). If a flare or other
combustion device is used to control emissions of volatile organic compounds to comply
with Section XVII, it shall be enclosed; have no visible emissions during normal
operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that
an observer can, by means of visual observation from the outside of the enclosed flare
or combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. This flare must be equipped with an
operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with
an operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion
device planned shutdown, whichever comes first.
COLORADO
Air Pollution Control Division
Department of Pubttc Health b tnvtronmertt
Page 3 of 9
12. rThe f•rnk cR£ ed b s per Nit is subject to the emission control requirements
II.C.1. The owner or operator shall install and
nt that achieves an average hydrocarbon control
ice is used, it must have a design destruction
efficiency of at least 98% for hydrocarbons except where the combustion device has
been authorized by permit prior to May 1, 2014. The source shall follow the inspection
requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the
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.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank
Emission Management System ("STEM") requirements of Regulation Number 7, Section
XVII.C.2.
OPERATING a MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (OEM) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to the O&M plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or
absence of visible emissions. "Visible Emissions" means observations of smoke for any
period or periods of duration greater than or equal to one minute in any fifteen -minute
period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part
A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
COPHE
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
COLORADO
Air Pollution Control Division
Department of RtPtic Neaith b Gnvfronment
Page 4 of 9
(VOC) and nitrogen oxides sources (NOx) in ozone
less than 100 tons of VOC or NO, per year, a
ns of one (1) ton per year or more or five percent,
gr - ��. �above level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major
modification solely by virtue of a relaxation in any enforceable limitation that was
established after August 7, 1980, on the capacity of the source or modification to
otherwise emit a pollutant such as a restriction on hours of operation (Reference:
Regulation Number 3, Part D, VI.B.4).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
20. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this
construction permit does not provide "final" authority for this activity or operation of
this source. Final authorization of the permit must be secured from the APCD in writing
in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation
Number 3, Part B, Section III.G. Final authorization cannot be granted until the
operation or activity commences and has been verified by the APCD as conforming in all
respects with the conditions of the permit. Once self -certification of all points has been
reviewed and approved by the Division, it will provide written documentation of such
final authorization. Details for obtaining final authorization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this
information and with representations made by the owner or operator or owner or
COLORADO
Air Pollution Control Division
Department of Pubtic tfea@n b Environment
Page 5 of 9
for the equipment and operations or activity
22. erwise the general and specific conditions contained in
pe fined '. he APCD to be necessary to assure compliance
with the provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by
the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or
the Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual
fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
James Ricci
Permit Engineer
Permit History
CDPH
l.�
Issuance
Date
Description
Issuance 1
This Issuance
Issued to HighPoint Operating Corporation.
New permit for crude storage at a synthetic
minor facility in the attainment area.
COLORADO
Air Pollution Control Division
Department of Public Heaith b Environment
Page 6 of 9
Notes 'r. Pe j' it r" • t -r at tim- ! his p mit issuance:
1) Th p.r fee : or the processing time for this permit. An invoice
foer the rmit is issued. The permit holder shall pay the
i wi 3' . o ` _ •" of t ' voice. Failure to pay the invoice will result in
revocation of this permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit
are based on the consumption rates requested in the permit application. These limits may
be revised upon request of the owner or operator providing there is no exceedance of any
specific emission control regulation or any ambient air quality standard. A revised air
pollution emission notice (APEN) and complete application form must be submitted with a
request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall
notify the Division of any malfunction condition which causes a violation of any emission
limit or limits stated in this permit as soon as possible, but no later than noon of the next
working day, followed by written notice to the Division addressing all of the criteria set
forth in Part II.E.1 of the Common Provisions Regulation. See:
https: / /www.colorado. gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of
the Division's analysis of the specific compounds emitted if the source(s) operate at the
permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
4090
205
Toluene
108883
2281
114
Ethylbenzene
100414
223
11
Xylenes
1330207
598
30
n -Hexane
110543
41963
2098
2,2,4-Trimethylpentane
540841
18
1
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission
rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees
based on the most recent Air Pollution Emission Notice.
COLORADO
Air Pollution Control Division
Department of Public Health & Enwionment
Page 7 of 9
Point 003:
it are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
NOx
2.59 x 10-3
2.59 x 10-3
AP -42
(Flares)
CO
1.18 x 10-2
1.18 x 10.2
VOC
1.34 x 10°
6.72 x 10"2
Flash
Liberation
Analysis +
TANKS
4.0.9d
71432
Benzene
2.73 x 10-3
1.36 x 104
108883
Toluene
1.52 x 10-3
7.60 x 10-5
100414
Ethylbenzene
1.49 x 10"4
7.44 x 10-6
1330207
Xylene
3.98 x 10-4
1.99 x 10-5
110543
n -Hexane
2.80 x 10-2
1.40 x 10"3
540841
2,2,4-Trimethylpentane
1.20 x 10-5
5.99 x 10-2
Note: The controlled emissions factors for this point are based on the enclosed combustor
control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)
associated with this permit is valid for a term of five years from the date it was received
by the Division. A revised APEN shall be submitted no later than 30 days before the five-
year term expires. Please refer to the most recent annual fee invoice to determine the
APEN expiration date for each emissions point associated with this permit. For any
questions regarding a specific expiration date call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule
805b(2)(A) when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, n -Hexane, Total HAPs
PSD
Synthetic Minor Source of: VOC, NOx
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http: / /ecfr. Qpoaccess. Rov/
COLORADO
Air Pollution Control Division
Department of Pubkc Heait:^, & Environment
Page 8 of 9
art • : ards i f erfo mince f New Stationary Sources
SPS .
0 En .
Subp. , t A - Subpart KKKK
;5
rt'.-�
Appendixes
Appen.x A - 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
COLORADO
Air Pollution Control Division
Department of Public Health fr Environment
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
James Ricci
386526
12/20/2018
1/29/2019
Section 01 - Facility Information
Company Name:
County AIRS ID:
HighPoint Operating Corporation
123
Quadrant
Section
Township
Range
NWNE
24
11N
63
Plant AIRS ID:
Facility Name:
Location:
County:
Type of Facility:
What industry segment?
9FCA
Critter Creek 24-1 Production Facility
NWNE Quadrant of Section 24, Township 11N, Range 63W
Weld County
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑ Carbon Monoxide (CO) O
Section 02 - Emissions Units In Permit Application
No
Particulate Matter (PM) ❑
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
003
Crude Oil Tank
Crude TKs
Yes
18WE0905.CP1
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
High Point Operating Corporation (HPOC) submitted an initial application containing APENs in August 2018. HPOC submitted updated APENs in December 2018 that were processed in lieu of
those in the initial application.
The Critter Creek 24-1 facility is a multi -well facility located in the attainment area,the facility is located North of the ozone non -attainment area. The facility serves the commingled liquid
stream (containing natural gas, crude oil and produced water) from fifteen (15) wells through 3 -phase inlet separators. The hydrocarbon liquid (crude oil) flows first to one (1) of two (2) heated
flash gas separators (oil polishers), each equipped with a 1.0 MMBtu/hr burner, where any entrained gases are allowed to flash from the liquid. The crude oil then flows to ten (10) 840 -bbl
atmospheric storage tanks. Flashing, working and breathing emissions off the crude oil storage tanks are sent to the enclosed combustion devices (ECDs).
HPOC is requested to permit the emmisions from the ten (10) 840 -bbl atmospheric storage tanks through this request.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here: 502
Prevention of Significant Deterioration (PSD) ❑
Title V Operating Permits (OP) ❑
Non -Attainment New Source Review (NANSR)
No
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ O O
❑ ❑ ❑ a ❑ O O a
O ❑
NOx CO VOC PM2.5 PM10 TSP HAPs
O O O O O
❑ ❑ ❑ O O O O
❑ O
Crude Oil Storage Tank(s) Emissions Inventory
003 Crude Oil Tank
Facility AIRS ID:
123
County
9FCA
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Ten (10) 840 -bbl fixed roof atmospheric tanks used to store crude oil
Emission Control Device
Eight (8) Used 48= Enclosed Combustors, 93% Manufacturer Guaranteed Control Efficiency
Description:
Requested Overall VOC & HAP Control
Efficiency %:
95
?iction 03 - Processing Rate Information for Emissions Estimates
Primary Emissions • Storage Tank(s)
Actual Throughput
Requested Permit Limit Throughput =
1,250,427 Barrels (bbl) per year
1,500,512 Barrels (bbl) per year Requested Monthly Throughput •
1,500412 Barrels (bbl) per year
Actual Crude Oil Throughput While Emissions Controls Operating • 1,250,427
127441 Barrels (bbl) per month
Potential to Emit (PIE) Throughput •
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced =
2349.0051
14.68031
Btu/scf
scf !bbl
Gross Heating Value from Flash Liberation
13.9 scf/bbl (Flash from Liberation Analyls) • 0.78 scf/bbl (W&B Estimation
from VOC weight percentages)
Pilot Fuel Usage =
5,481
MMBTU per year
Actual heat content of waste gas routed to combustion device = I
48,601
MMBTU per year
Requested heat content of waste gas routed to combustion device •
57225
MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
57225
MMBTU per year
Section 04 - Emission Factors & Methodologies
Will this storage tank emit flash emissions?
FPI
Emission Factors
Crude Oil Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (Ib/bbl)
Emission Factor Source
(Crude Oa
Throughput)
(Crude Oil
Throughput)
VOC
1.343
0.07
Site Specific E.F. (Includes flash)
Site Specifk E.F. (includes (lash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Sae Specific E.F. (includes flash)
Semen*
0.0027
0.000
Toluene
0.00152
0.000
Ethylbenzene
0.00015
0.000
Xylene
0.00040
0.000
n -Hexane
0.02797
0.001
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
224 TMP
0.00001
0.000
Polutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu) (Ib/bbl)
(waste heat
combusted)
(Crude Oil
Throughput)
PMIO
0.0075
0 0003
AP -42 Table 1.4-2 (PM10/PM2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP42 Chapter 13.5 industrial Flares (NOR)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
0 0003
NOx
0.0680
0.0023
CO
0.3100
0.0107
}talon OS - Emissions Inyentoty
W&B (lb/bbl) from
TANKS
Flash (lb/bbl)
from Liberation
0.071521
1.271.542223
0.000145154
0.002580632
8.09545E-05
0.001439261
7.92244E-06
0.00014085
2.12176E-05
0.000377219
0.001489236
0.026476567
6.37437E-07
1.13328E-05
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM23
NOx
CO
1007.6
639.7
42.0
1007.5
50 7
8553
0.2
0.2
0.2
0.2
0 2
36
0.2
0.2
0.2
0.2
0.2
36
1.9
1.7
1.7
1.9
1.9
330
8.9
7.5
7.5
8.9
8 9
1507
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ito/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benton•
Toluene
Ethylbenzene
Xylem*
n -Hexane
224 TN?
4090
3408
170
4090
205
2281
1901
95
2281
11.4
223
186
9
223
11
598
498
25
598
30
41961
34969
1748
41961
2098
18
15
1
18
1
jectlon 06 - Regulatory Summary Analysis
3891.289884
17739.70388
2.59E-03
1.18E-02
W&B
W&B
(MMBTU/yr)
(sc/obi)
2291.981858
C.78031
Regulation 3. Parts A.B
Source requires a permit
Regulation 7. Section XVII.B, C.1, C3
Storage tank is subject to Regulation 7, Section XVII, 8, C.1 & C-3
Regulation 7, Section XV1I.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A. NSPS Subpart Kb
Storage Tank is not subject to FISPS Kb
Regulation 6, Part A. NSPS Subpart 0000
Storage Tank is nut subject to NSPS 0000
Regulation 8. Part E. MACT Subpart HH
Store;o Tank it not subject to MACT HH
(See regulatory applicability worksheet for detaaed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03
Does the company use a site specific emissions factor to estimate emissions?
Yes
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the
facility being permitted?rrt�,ti;
if no, the permit will contain an 'initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines In PS Memo 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
N/A
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 Analyse Notes
A sample of Polished Oil was taken at the Critter Creek 24-1 Facility on 6/26/2018 and analyzed by Air Pollution Testing Inc. on 7/3/2018. The sample was flashed from 134degF & 2lpsug to 106degF & 12.2psia resulung
in 13.9 scf flashed gas/bbl of stock tank liquid. The applicant confirmed with the testing company that the flash liberation results are already converted to standard conditions.
TANKS was used assuming a RVP=6 to estimate VOC W&6 losses. Weight percentages were used from the flash liberation analysis to estimate HAP W&B losses using the VOC W&B emissions from TANKS.
Waste Gas was calculated by adding flashed gas (from the flash liberation analysis) to an estimation of W&B waste gas. W&8 waste gas was daculted as follows:
( Xf Btu rcon 15 1 SCF Gas I Brul /1N118tu1
Flash Gas Yr. = Uncontr oiled VOC l Yr x 2000 tan x Gas .7f14r x 37 F,41 lb • mast x (VOC 9G 1 x Haat Content tSCFI x 1 110'81u/
The stock tank liquid was analyzed resulting in a API gravity of 353. This was confirmed with COGCC Production Data. Looking at 3 random production points, they were all between 35-36 API gravity.
Section 09 • Inventory SCC Coding and Emissions Factors
AIRS Point
XCi
Process I SCC Code
01
*Aaa;r,0iAt; !!NO * . 'crot t
Uncontrolled
Pollutant Emissions Factor Control% Links
PM10 D.C1 0 lb/1,000 gallons aside oil thraighput
PM25 0.01 0 lb/1,000 gallons crude oil throughput
NOx 0.06 0 lb/1,000 gallons crude oil throughput
VOC 32.0 95 lb/1,000 gallons attic oil throughput
CO 0.28 0 lb/1,000 gallons aside dl throughput
Benzene 0.06 95 lb/1,000 gallons crude oil throughput
Toluene 0.04 95 lb/1,000 gallons crude oil throughput
Ethylbenzene 0.00 95 lb/1,000 gallons crude oil throughput
Xylene 0.01 95 lb/1,000 gallons crude oil throughput
n -Hexane 0.67 95 lb/1,000 gallons aide oil throughput
224 IMP 0.00 95 lb/1.000 gallonsatde oii throughput
2of4
K:\PA\2018\ 18 WE0905.CD 1 alsm
Crude Oil Storage Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)?
2a. If answer to #2 is yes, is the crude oil storage tank capacity less than 40,000 gallons per year?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Yes Source Req
No
NA
Yes
Source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)?
2a. If answer to #2 is yes, is the crude oil storage tank capacity less than 40,000 gallons per year?
3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
You have indicated that source is in the Attainment Area
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility`, natural gas compressor station 3 or natural gas processing plant?
3. Is this crude oil storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions" of this storage tank equal to or greater than 6 tons per year VOC?
No
Yes
Yes
Yes
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
No
Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) ["'472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ("'10,000 BBL] used for petroleum) or condensate stored, processed, or treated prior to custody transfer? as defined in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL) as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ["'29.7 psi] and without emissions to the atmosphere (60.11ob(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 [^'950 BBL] and stores a liquid with a maximum true vapor pressure° less than 3.5 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 ["472 BBL] but less than 151 m3 ("950 BBL] and stores a liquid with a maximum true vapor pressure° less than 15.0 kPa(60.11ob(b))?
Yes
Yes
NA
NA
NA
NA
Go to next
Source Req
Continue -'
Continue - •
Go to the n
Source is st
Source is st
Go to the n
Storage Tat
Storage Tank is not subject to NSPS K
D
Subpart A, General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b - Reporting and Recordkeeping Requirements
§60.116b - Monitoring of Operations
40 CFR, Part 60, Subpart OOOO, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this crude oil storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions? from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this crude oil storage vessel meet the definition of "storage vessel": per 60.5430?
NA
NA
NA
No
NA
NA
Storage Tank is not subject to NSPS OOOO
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
*60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids? (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (63.760(a)(3))?
1. Is the tank located at a facility that is majors for HAPs?
3. Does the tank meet the definition of "storage vessel"4 in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO?
Storage Tank is not subj
ect to MACT HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any
law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations. and Air Quality Control Commission regulations. the language of the statute or regulation will control. The use of non -mandatory language such as `recommend,- "may,"
"should. 'S and "can,- is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required- are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
No
NA
NA
NA
Continue
Storage Tar
Continue -
Storage Tar
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
Q= Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
MW
44.2992
Ib/Ib-mol
Throughput
1500512
bbl/year
Gas -to -Oil Ratio (GOR)
13.87
scf/bbl
mass fraction (%)
Emission Factor (lb/bbl)
Emissions (lbs/year)
Helium
0.00
0.000E+00
0.00
CO2
1.25
2.027E-02
30416.99
N2
6.87
1.113E-01
166978.83
H2S
0.00
0.000E+00
0.00
methane
2.88
4.661E-02
69934.04
ethane
10.46
1.693E-01
253983.40
propane
33.82
5.475E-01
821581.69
isobutane
5.82
9.426E-02
141437.40
n -butane
20.65
3.343E-01
501672.55
isopentane
4.85
7.848E-02
117759.23
n -pentane
6.05
9.802E-02
147080.61
cyclopentane
0.56
9.068E-03
13606.38
n -Hexane
1.64
2.6477E-02
39728.41
cyclohexane
0.34
5.577E-03
8368.86
Other hexanes
2.76
4.465E-02
67001.91
heptanes
0.89
1.440E-02
21606.00
methylcyclohexane
0.28
4.478E-03
6719.38
224-TMP
0.00
1.133E-05
17.00
Benzene
0.16
2.58063E-03
3872.27
Toluene
0.09
1.43926E-03
2159.63
Ethylbenzene
0.01
1.409E-04
211.35
Xylenes
0.02
3.772E-04
566.02
CS
0.32
5.194E-03
7793.12
C9
0.04
6.670E-04
1000.86
C10
0.24
3.853E-03
5781.68
C11+
0.00
0.000E+00
0.00
Total
100.00
,a° 'A*
:
;
IA
VOC Wt %
78.54
1.272E+00
953.98218
n -Hexane
224 -TM P
Benzene
Toluene
Ethylbenzene
Xylenes
Total
GOR Conversion Check
Actual Pressure (P1)
12.2
psia
Actual Temperature (T1)
565.67
Rankine
Actual GOR (V1)
13.9
cf/bbl
Standard Pressure (P2)
14.65
psia
Standard Temperature (T2)
519.67
Rankine
Standard GOR (V2)
10.63412
scf/bbl
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0906 Issuance: 1
HighPoint Operating Corporation
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Critter Creek 24-1 Production Facility
123/9FCA
NWNE Quadrant of Section 24, Township 11N, Range 63W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
Loadout
004
Truck loadout of crude oil by submerged fill
Enclosed Combustor
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq),
to the specific general terms and conditions included in this document and the following
specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen
days of the latter of commencement of operation or issuance of this permit, l
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/cdphe/air/manage-permit. Failure to notify the Division of startup
of the permitted source is a violation of Air Quality Control Commission (AQCC)
Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the
permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, compliance with the conditions contained in this permit shall
be demonstrated to the Division. It is the owner or operator's responsibility to self -
certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. A self certification form and guidance on
how to self -certify compliance as required by this permit may be obtained online at
COLORADO
Air Pollution Control Division
Department of Pubic[ Health & Environment
Page 1 of 10
www.colorado. • ov/cd • he � t-- � _ tific. •' '. egu ti. Num � r 3, Part B,
Section III.G.2.)
3. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the
date on which such construction or activity was scheduled to commence as set forth in
the permit application associated with this permit; (ii) discontinues construction for a
period of eighteen months or more; (iii) does not complete construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations. (Reference:
Regulation Number 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
Loadout
004
--
0.2
4.5
0.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0
tons per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all
permitted emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve
month total is calculated based on the previous twelve months' data. The permit holder
shall calculate actual emissions each month and keep a compliance record on site or at
a local field office with site responsibility for Division review.
6. The emission points in the table below shall be operated and maintained with the
emissions control equipment as listed in order to reduce emissions to less than or equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
Loadout
004
Enclosed Combustor
VOC and HAP
COLORADO
Air Pollution Control Division
Department of Pub:to Health & Environment
Page 2 of 10
PROCESS LIMITATIONS AND REC
7. This source shall be limi = fog � E m rates :. ed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation Number 3, Part B, II.A.4)
Process/Consumption Limits
Facility
Equipment
ID
AIRS
point
Process Parameter
Annual Limit
Loadout
004
Crude Oil Loaded
1,500,512 barrels
The owner or operator shall calculate monthly process rates based on the calendar
month.
Compliance with the annual throughput limits shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve-month total is calculated
based on the previous twelve months' data. The permit holder shall calculate
throughput each month and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
8. Loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation
Number 3, Part B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. No owner or operator of a smokeless flare or other flare for the combustion of waste
gases shall allow or cause emissions into the atmosphere of any air pollutant which is in
excess of 30% opacity for a period or periods aggregating more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.5.)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. All hydrocarbon liquid loading operations, regardless of size, shall be designed,
operated and maintained so as to minimize leakage of volatile organic compounds to
the atmosphere to the maximum extent practicable.
12. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.D.2):
a. The owner or operator shall inspect onsite loading equipment to ensure that
hoses, couplings, and valves are maintained to prevent dripping, leaking, or
other liquid or vapor loss during loading and unloading. The inspections shall
occur at least monthly. Each inspection shall be documented in a log available
to the Division on request.
b. All compartment hatches at the facility (including thief hatches) shall be closed
and latched at all times when loading operations are not active, except for
periods of maintenance, gauging, or safety of personnel and equipment.
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Page 3 of 10
c. Inspect thief hatc ssary. Thief
hatch covers shall
d. Inspect pressure relief devices (PRD) annually for proper operation and replace
as necessary. PRDs shall be set to release at a pressure that will ensure flashing,
working and breathing losses are not vented through the PRD under normal
operating conditions.
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 shall follow loading
procedures that minimize the leakage of VOCs to the atmosphere including, but not
limited to (Reference: Regulation 3, Part B, III.D.2):
a. Install and operate the vapor collection and return equipment to collect vapors
during loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in
use.
c. Use operating procedures to ensure that hydrocarbon liquid cannot be
transferred unless the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back -pressure less than the
pressure relief valve setting of transport vehicles.
OPERATING Et MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (O&M) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the
requirements of this permit. Revisions to your O&M plan are subject to Division
approval prior to implementation. (Reference: Regulation Number 3, Part B, Section
III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part
A, II.C.)
COLORADO
Air Pollution Control Division
Department of Pubitc Health & Env ronment
Page 4 of 10
• Annually by April
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual
emissions of five (5) tons per year or more, above the level reported on
the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.)
in ozone nonattainment areas emitting less than 100 tons of VOC or NO,
per year, a change in annual actual emissions of one (1) ton per year or
more or five percent, whichever is greater, above the level reported on
the last APEN; or
For sources emitting 100 tons per year or more, a change in actual
emissions of five percent or 50 tons per year or more, whichever is less,
above the level reported on the last APEN submitted.
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is
less, above the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or
activity; or
• Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that
any stationary source or modification becomes a major stationary source or major
modification solely by virtue of a relaxation in any enforceable limitation that was
established after August 7, 1980, on the capacity of the source or modification to
otherwise emit a pollutant such as, a restriction on hours of operation (Reference:
Regulation Number 3, Part D).
GENERAL TERMS AND CONDITIONS
19. This permit and any attachments must be retained and made available for inspection
upon request. The permit may be reissued to a new owner by the APCD as provided in
AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
. 20. If this permit specifically states that final authorization has been granted, then the
remainder of this condition is not applicable. Otherwise, the issuance of this
construction permit does not provide "final" authority for this activity or operation of
this source. Final authorization of the permit must be secured from the APCD in writing
in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation
Number 3, Part B, Section III.G. Final authorization cannot be granted until the
operation or activity commences and has been verified by the APCD as conforming in all
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 5 of 10
respects with the conditio ce s =ifica in f all pis has been
reviewed and approved b isio it =≥ l • ;'vide r itte n documen . tion of such
final authorization. Detai s or obtaining fina aut orization to operate are located in
the Requirements to Self -Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information
supplied by the owner or operator and is conditioned upon conduct of the activity, or
construction, installation and operation of the source, in accordance with this
information and with representations made by the owner or operator or owner or
operator's agents. It is valid only for the equipment and operations or activity
specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in
this permit have been determined by the APCD to be necessary to assure compliance
with the provisions of Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by
the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or
the Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual
fee billing will terminate.
25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution
Prevention and Control Act or the regulations of the AQCC may result in administrative,
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
James Ricci
Permit Engineer
COPHE
C
COLORADO
Air Pollution Control Division
Department of Public Heaim & Environment
Page 6 of 10
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to HighPoint Operating Corporation.
New permit for crude loadout at a synthetic
minor facility in the attainment area.
COLORADO
Mr Pollution Control Division
Deeartnvnt of Pubic Neaktn & Environment
Page 7 of 10
Notes to Permit Holder at the ti
1) The permit holder is require zti - - eeshe = 9 sin his peAn invoice
for these fees will be issued after the permit is issued. The permit holder shall pay the
invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in
revocation of this permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit
are based on the consumption rates requested in the permit application. These limits may
be revised upon request of the owner or operator providing there is no exceedance of any
specific emission control regulation or any ambient air quality standard. A revised air
pollution emission notice (APEN) and complete application form must be submitted with a
request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall
notify the Division of any malfunction condition which causes a violation of any emission
limit or limits stated in this permit as soon as possible, but no later than noon of the next
working day, followed by written notice to the Division addressing all of the criteria set
forth in Part II.E.1 of the Common Provisions Regulation. See:
https: / /www.colorado. gov/ pacific /cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of
the Division's analysis of the specific compounds emitted if the source(s) operate at the
permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
004
Benzene
71432
364
18
Toluene
108883
203
10
Ethylbenzene
100414
20
1
Xylenes
1330207
53
3
n -Hexane
110543
3733
187
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.
COLORADO
Air Pollution Control Division
Department of Public Health S Environment
Page 8 of 10
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
NOx
2.07 x 10-4
AP -42 (Flares)
CO
9.43 x 10-4
VOC
1.19 x 10-'
5.97 x 10-3
AP -42, Chapter
5.2, Equation 1
+ Engineering
Estimate for
HAPS
Benzene
71432
2.42 x 10-4
1.21 x 10-5
Toluene
108883
1.35 x 10-4
6.76 x 10-6
Ethylbenzene
100414
1.32 x 10-5
6.62 x 10-'
Xylene
1330207
3.54 x 10-5
1.77 x 10-6
n -Hexane
110543
2.49 x 10-3
1.24 x 10-4
2,2,4-Trimethylpentane
540841
1.06 x 10-6
5.32 x 10-8
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation
1 (version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 2.824 psia
M (vapor molecular weight) = 69 lb/lb-mol
T (temperature of liquid loaded) = 512.45 °R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were
calculated by multiplying the mass fraction of each NCRP in the flashed crude vapors by
the VOC emission factor.
Controlled emission factors are based on a flare efficiency of 95% and a collection
efficiency of 100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN)
associated with this permit is valid for a term of five years from the date it was received
by the Division. A revised APEN shall be submitted no later than 30 days before the five-
year term expires. Please refer to the most recent annual fee invoice to determine the
APEN expiration date for each emissions point associated with this permit. For any
questions regarding a specific expiration date call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, n -Hexane, Total HAPs
PSD
Synthetic Minor Source of: VOC, NOx
DPHE
ter
COLORADO
Air Pollution Control Division
Department of Public Heatth Er Environment
Page 9 of 10
8) Full text of the Title 40, Prot
can be found at the website li
http://ecfr.gpoaccess.gov/
Regulations
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60,
Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
James Ricci
386526
12/20/2018
1/29/2019
Section 01 - Facility Information
Company Name:
County AIRS ID:
HighPoint Operating Corporation
123
Quadrant
Section
Township
Range
NWNE
24
11N
63
Plant AIRS ID:
Facility Name:
Location:
County:
Type of Facility:
What industry segment?
9FCA
Critter Creek 24-1 Production Facility
NWNE Quadrant of Section 24, Township 11N, Range 63W
Weld County
Exploration & Production Well Pad
Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑
Section 02 - Emissions Units In Permit Application
Carbon Monoxide (CO)
❑ Particulate Matter (PM) ❑ Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
004
Liquid Loading
Loadout
Yes
18WE0906.CP1
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
High Point Operating Corporation (HPOC) submitted an initial application containing APENs in August 2018. HPOC submitted updated APENs in December 2018 that were processed in lieu of
those in the initial application.
The Critter Creek 24-1 facility is a multi -well facility located in the attainment area (the facility is located North of the ozone non -attainment are)a. The facility serves the commingled liquid
stream (containing natural gas, crude oil and produced water) from fifteen (15) wells through 3 -phase inlet separators. The hydrocarbon liquid (crude oil) flows first to one (1) of two (2) heated
flash gas separators (oil polishers), each equipped with a 1.0 MM8tu/hr burner, where any entrained gases are allowed to flash from the liquid. The crude oil then flows to ten (10) 840 -bbl
atmospheric storage tanks
Once adequate volumes are accumulated, the crude oil is measured, loaded into a tank truck and sold. The crude oil is submerge -filled as it is loaded into the truck. As the crude oil is pumped
into the truck, the fluid displaces the vapors. The displacement causes the vapors to vent from inside the truck to the atmosphere. -IPOC is requsting to permit the emissions that occur during
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why?
Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits (OP) ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑
Non -Attainment New Source Review (NANSR) El O
No
Yes
5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ a ❑ ❑
❑ ❑ ❑ a ❑ ❑ LI o
❑ ❑
No
Hydrocarbon Loadout Emissions Inventory
004 Liquid Loading
Facility AIRs ID:
123
County
9FCA
Plant
004
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Truck loadout of crude oil by submerged fill
Emission Control Device
Eight (8) Leed 48" Enclosed Combustors, 98% Manufacturer Guaranteed Control Efficiency
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Yes
100.0
95
Requested Overall VOC & HAP Control Efficiency %: 95.00
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
1,250,427
Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
1,250,427 Barrels (bbl) per year
Requested Permit Limit Throughput = 1,500,512 Barrels (bbl) per year
Requested Monthly Throughput =
127441 Barrels (bbl) per month
Potential to Emit (PTE) Volume Loaded =
1,500,512
Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = 2349.0051 Btu/scf
Volume of waste gas emitted per year = 1943471 scf/year
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
Loading Loss Equation
L = 12.46'S'P'M/T
Gross Heating Value from Flash Liberation
3,804 MMBTU per year
4,565 MMBTU per year
4,565 MMBTU per year
4565.223223
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0 ;
`j t
P
True Vapor Pressure
2.824
psia
Value was taken from TANKS assuming RVP = 6. A nearly identical value was found using AP-
42 Figure 7.1-13a.
M
Molecular Weight of Vapors
69
Ib/Ib-mol
Value was taken from TANKS assuming RVP = 6. This assumption is higher than using AP -42
Table 7.1-2, this a conservative estimation.
T
Liquid Temperature
512.12
Rankine
Value was taken from TANKS assuming the site is in Denver, CO. Thie temperatre is the
calculated liquid bulk temperature
L
Loading Losses
2.844535375
lb/1000 gallons
0.119470486 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0.00203
0.000242469
lb/bbl
Mass fractions taken from Flash Liberation of Crude as conservative estimation
Toluene
0.00113
0.000135229
lb/bbl
Mass fractions taken from Flash Liberation of Crude as conservative estimation
Ethylbenzene
0.00011
1.32339E-05
lb/bbl
Mass fractions taken from Flash Liberation of Crude as conservative estimation
Xylene
0.00030
3.54424E-05
lb/bbl
Mass fractions taken from Flash Liberation of Crude as conservative estimation
n -Hexane
0.02082
0.002487663
lb/bbl
Mass fractions taken from Flash Liberation of Crude as conservative estimation
224 TMP
0.00001
1.06479E-06
lb/bbl
Mass fractions taken from Flash Liberation of Crude as conservative estimation
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
1.19EO1
5.97E-03
Site Specific - AP -42: Chapter 5.2, Equation 1
Benzene
2.42E-04
1.21E -0S
Site Specific - AP -42: Chapter 5.2, Equation 1
Toluene
1.35E-04
6.76E-06
Site Specific - AP -42: Chapter 5.2, Equation 1
Ethylbenzene
1.32E-05
6.62E-07
Site Specific - AP -42: Chapter 5.2, Equation 1
Xylene
3.54E-05
1.77E-06
Site Specific - AP -42: Chapter 5.2, Equation 1
Site Specific - AP -42: Chapter 5.2, Equation 1
Site Specific - AP -42: Chapter 5.2, Equation 1
n -Hexane
2.49E-03
1.24E-04
224 TMP
1.06E-06
5.32E-08
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(Ib/MMBtu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM10
0.0075
2.27E -0S
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (PM10/PM.2.5)
AP -42 Table 1.4-2 (SOx)
AP -42 Chapter 13.5 Industrial Flares (NOx)
AP -42 Chapter 13.5 Industrial Flares (CO)
PM2.5
0.0075
2.27E-05
SOx
0.0006
1.79E-06
NOx
0.0680
2.07E-04
CO
0.3100
9.43E-04
Flash (lb/bbl)
from Liberation
VOC
1.271542223
Benzene
0.002580632
Toluene
0.001439261
Ethylbenzene
0.00014085
Xylene
0.000377219
n -Hexane
0.026476567
224 TMP
1.13328E-05
r. t 4
K:\PA\2018\18W E0906.CP1.xlsm
Hydrocarbon Loadout Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
0.02
0.01
0.01
0.0
0.0
3
PM2.5
SOx
0.02
0.01
0.01
0.0
0.0
3
0.00
0.00
0.00
0.0
0.0
0
NOx
0.16
0.13
0.13
0.2
0.2
26
VOC
89.63
74.69
3.73
89.6
4.5
761
CO
0.71
0.59
0.59
0.7
0.7
120
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
364
303
15
364
18
Toluene
203
169
8
203
10
Ethylbenzene
20
17
1
20
1
Xylene
53
44
2
53
3
n -Hexane
3733
3111
156
3733
187
224 TMP
2
1
0
2
0
Section 06 - Regulatory Summary Analysis
310.4351791
1415.219199
2.07E-04
9.43E-04
Regulation 3, Parts A, B
Source requires a permit
RAG - Regulation 3, Part B, Section III.D.2.a
Site is in attainment and not subject to RACT
jl
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
No
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
Waste Gas was calculated using the following equation, VOC percentages and MW was found from the flash liberation analysis:
Flash Gas l = Uncontrolled VOC (yj10x2000( !6 x ' x379.41 SCFGas x( t xHeatContent (f3tu x11�f►fetu
\ yr / \ton/ Gas MW lb•mol \VOC % \SCF l06FJtu
The method of using ratios from the flash liberation analysis was accepted since they resulted in higher emission factors than the state approved ones.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
004
Process #
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
Pollutant
PM10
PM2.5
SOx
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.00
0.00
0.00
0.00
2.8
0.02
0.01
0.00
0.00
0.00
0.06
0.00
Control % Units
0 lb/1,000 gallons transferred
0 lb/1,000 gallons transferred
0 lb/1,000 gallons transferred
0 lb/1,000 gallons transferred
95 Ib/1,000 gallons transferred
0 lb/1,000 gallons transferred
95 lb/1,000 gallons transferred
95 Ib/1,000 gallons transferred
95 lb/1,000 gallons transferred
95 lb/1,000 gallons transferred
95 Ib/1,000 gallons transferred
95 lb/1,000 gallons transferred
3 of 4 K:\PA\2018\18WE0906.CP1.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
Yes
Yes
No
No
No
Yes
Source requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
You have indicated that source is in the Attainment Area
7. RAG - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?
Site is in attainment and not subject to RACT
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable_ In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend," "may,"
"should, " and "can." is intended to describe APCD interpretations and recommendations Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under the
terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
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The loadout requires a per
Crude Oil Storage Tank(s) APEN
Form APCD-210
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the
General APEN (Form APCD-2OO) 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.Qov/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.
DEC
Permit Number:
AIRS ID
123 / 9FCA / 003
1 8WE0905 Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
HighPoint Operating Corporation
Critter Creek 24-1 Production Facility
Site Location
NWNE Section 24 T11 N R63W County: Weld
MailingAddress:
Zip Code)
(Include 1099 18th St. Suite 2300
Denver, CO 80202
NAICS or SIC Code: 1311
Contact Person: Marsha Sonderfan
Phone Number: 303-312-8524
E -Mail Address2: CDPHE_Corr@hpres.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
391506
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 1 I AV
COLORADO
a Public
HNpr Etrivli vrw RI
Permit Number: 18WE0905 AIRS ID Number: 123 / 9FCA/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under General Permit GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
O MODIFICATION to existing permit (check each box below that applies)
O Change in equipment ❑ Change company name'
❑✓ Change permit limit O Transfer of ownership4 O Other (describe below)
- OR
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t Notes: Permit Modification for the addition of nine (9) new wells producing to the facility.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Crude Oil Tank Battery
Company equipment Identification No. (optionaO:
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 9/26/2018
Normal Hours of Source Operation: 24
hours/day 7 days/week 52
weeks/year
nk(s) located at: ❑✓ Exploration Et Production (MP) site ❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
■
Yes
I9
No
Are Flash Emissions anticipated from these storage tanks?
•
Yes
■
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
II
Yes
Igl
No
Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
GI
Yes
■
No
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
21 AY
COLORADO
Department of WNic
Permit Number: 18WE0905
AIRS ID Number: 123 / 9FCA/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Crude Oil Throughput:
Actual Annual Amount
(bbl/year).
1,250,427
Requested Annual Permit Limits
(bbl /year)
1,500, 512
From what year is the actual annual amount?
Average API gravity of sales oil: 35.3
Tank design: ❑✓ Fixed roof
2018
degrees
0 Internal floating roof
RVP of sales oil: 5.8
❑ External floating roof
Storage
Tank ID
Crude TKs
# of Liquid Manifold Storage
Vessels in Storage Tank
10
Total Volume of
Storage Tank
(bbl)
8,400
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
May 2018
Date of First
Production. ._
(month/year).
May 2018
Wells Serviced by this Storage Tank or Tank Batteryb. (EEP Sites On y) - -
- ... .r.� .......
y , API Number.'•:; .;
- -
- ::.....,..: Name of Well . = . ...;-.
' Newly Reported Well
-
See attached well list (Addendum)
•
■
■
■
■
5 Requested values will become permit limitations. Requested timit(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 wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.914711 / -104.377547
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F) . ,
Flow Rate
(ACFM).
Velocity
(ft/sec)
.
ECD
TBD
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward
0 Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
❑ Square/rectangle
❑ Other (describe):
Interior stack diameter (inches):
Interior stack width (inches):
0 Upward with obstructing raincap
48
Interior stack depth
(inches):
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
Deprtmenx
COLORADO
alPubilc
Hw1+h S EnVII4Vmes!
Permit Number: 1 8WE0905
AIRS ID Number: 123 I 9FCA / 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
O Recovery
Unit (VRU):
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: 6.52 MMBtu/hr
Type: ECD Make/Model: Leed 48"
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,349.01 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.63 MMBtu/hr
O Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 21.4 psig
Describe the separation process between the well and the storage tanks: Crude oil from the 3 -phase
inlet separators goes to the heated flash gas separators (oil polishers) and to the storage tanks.
Form APCD-210 - Crude Oil Storage Task(s) APEN - Revision 7/2018
4 l A;COLORADO
Y 1=77
Permit Number: 18WE0905 AIRS ID Number: '123 / 9FCA/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
veIauI,UJ Willi -Hi mu)
Pollutant
1.V11uV6C[iRn-„.-? vnr:raa d.....:,.
Description of Control Method(s)..
Overall Requested Con trill
Efficiency. :
. (9S reduction in emissions)
V0C
ECD
95%
NOx
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? 2018
G6�t�eria Pollutant Emissions anvento _
rY ;
, :-:..:..--
Pollutant:
- ..... rni
Emission
:.
.,.:
-..
A ctualAnnual Emission 'l•:,•
:.v 1.'Perrriit •
Regaested:Aiiiriva
-.. Emission Limit(s)
.... ., ........7.:..:'_:._.
.. Factor.
-.. ,..:- ...:..
Uncontrolled
Uncontrolled
n.
Basis .
Units
Units-
. .. •
ou a
CAP 42
-.: (AP -42,
Mt.; etc. }
controlled
• Uncontrolled
Emissions•
(tons/yeai)
cont&1ed
Controlled
`" Emission$'
(foitslyear)::
Uictrolled
ncentrolle
UEmissionsd
(tons/year)
Coriti•olied
ControIl
Emissions' ''
(Yanslyear}
VOC
1.3435
lb/bbl
Eng. Est.
839.98
42.00
1,007.98
50.40
NOx
0.068
Ib/MMBtu
AP -42
1.65
1.94
CO
0.31
Ib/MMBtu
AP -42
7.52
8.85
Pollutan`i:--Em�sstohs'Invento
Factor :. =
..:_._.- No- n-Criteraa_Reportable
�..•.:.. • Emission
_--,-...,„-•_ _ -_._. -:
. _...... Actual Annual Emissions;..
:... :..:
.:.: Chemical Name:.
..: .......... ___ ..,... ..
' - Chemical's :
. Abstract .....''
- .- i
SerY7ce.(CAS)_.::.,-.-.:
Number.
':: .. :.
Uncontrolled.
Basis --
51s
.-..
.-Units........._(kP-42,._..:
ource -
Mfg.; etc.) •
Uncontrolled ::
1. '.
�.._.. Emissions '.._
. (pounds/year) m
. Control e8
...Emissions:.._ ..
(pounds/year) ..•
170.49
Benzene
71432
0.0027 .
lb/bbl
Eng. Est.
3,409.88
Toluene
108883
0.0015
lb/bbl
Eng. Est.
1,901,98
95.10
Ethylbenzene
100414
Xylene
1330207
0.0004
lb/bbl
Eng. Est.
499.05
24.95,
n -Hexane
110543
0.0280
lb/bbl
Eng. Est.
34,980.76
1,749.04
2,2,4-
Trimethylpentane
540841
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
COLORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
51
Permit Number: 18WE0905 AIRS ID Number: 123 / 9FCA/ 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source
is and will be operated in full compliance with each condition of the applicable General Permit.
ig-
Signature of Legally Authorize≥ Person (not a vendor or consultant) Date
Marsha Sonderfan
EHS Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
6 I
{Q$I COLORADO
17 ply dWNlc
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.00lorado.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: 18WE0906
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
AIRS ID Number: 123 / 9FCA / 004.
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Critter Creek 24-1 Production Facility
Site Location: NWNE Section 24 T11 N R63W
Mailing Address:
p Code1099 18th St. Suite 2300
(Include Zip Code)
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
Marsha Sonderfan
303-312-8524
CDPHE_Corr@hpres.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.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
391307
'COLORADO
Depastra&ns Pain.
HwF4i 4Petrenmem
Permit Number: 18WE0906 AIRS ID Number: 123 / 9FCA / 004
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly -reported emission source
O Request coverage under construction permit ❑ 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-
Q MODIFICATION to existing permit (check each box below that applies)
O Change fuel or equipment O Change company name3
✓❑ Change permit limit ❑ Transfer of ownership4 O Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
Permit Modification for the addition of nine (9) new wells producing to the facility.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Crude Oil Loading
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 9/26/2018
Will this equipment be operated in any NAAQS nonattainment area?
•
Yes
IS
No
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
l7
Does this source load gasoline into transport vehicles?
•
Yes
•
No
Is this source located at an oil and gas exploration and production site?
0
Yes
•
No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
0
Does this source splash fill less than 6750 bbl of condensate per year?
■
Yes
0
No
Does this source submerge fill less than 16308 bbl of condensate per year?
•
Yes
•
No
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
21 AY
COLORADO
Depart:mem
ham Er.Imsmer.
Permit Number: 18WE0906 AIRS ID Number: 123 I 9FCA /004
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑✓ Crude Oil O Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
1,500,512
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")
1,250,427
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
0.6
Average temperature of
bulk liquid loading:
C1
52.45
°F
True Vapor Pressure:
2.824
Psia ® 60 °F
Molecular weight of
displaced vapors:
69
lb/lb mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft'
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
3I
COLORADO
tegument ent d Public
Hon E €nHNcurent
Permit Number: 18WE0906
AIRS ID Number: 123 / 9FCA / 004
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.914711 / -104.377547
Operator
Stack ID No
Discharge Height Above
Ground Level
(feet) -
Temp.
(`F)
Flow Rate
(ACFAV
Velocity
(ft/sec)
ECD
TBD
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
0 Upward
O Horizontal
O Downward
O Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
O Other (describe):
O Upward with obstructing raincap
Interior stack diameter (inches): 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.
O Loading occurs using a vapor balance system: Requested Control Efficiency:
❑ Combustion
Device:
Used for control of: VOC, HAPs
Rating: 0.52
Type: ECD
MMBtu/hr
Make/Model: Leed 481!
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: °F Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating:
2,349.01
0.63
Btu/scf
MMBtu/hr
O Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4 I
COLORADO
Dc, ,=W,:°tPritLa
Hunt rri9,M,n..
Permit Number: 1 8WE0906
AIRS ID Number: 1 23 / 9FCA / 004
[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
overau forcompmneui
Pollutant
WIILIU1 etiiLIOtIs-y voICvtfUL:V::t•
Description of Control Method(s)
Overall Requested -
Control Efficiency
(% reduction in emissions)
PM
SOx
NOx
CO
VOC
ECD
95%
HAPs
ECD
95%
Other:
❑ . Using State Emission Factors (Required for GP07) VOC
❑ Condensate 0.236 Lbs/BBL
❑ Crude 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?
2018
,.......a._ .._,.. _..__ _e-_
_.�_....:,_..__ .
---•---.—.•
�.`
....�...:_.
7Pollutant--.:_..
___._-__..__,__.._m._...._'::.__._.____.._.-__.;..:_.Source-
.-
_...._..... �_.__.. __�-.::..:.:•-•-:-.--::-�w �.__. w
. :._... .` Emi mission Factor,':'" a •.::":�.:.
_ w.. ....._ :.
..
Actual Annual. Emtssions:: =:
_-.._._ ._
.... � .
� Requested Annual Permtt.
',:..- si _ s_-___
... mission Ltmtt s .�........
Em gym..
--
-:...,.___.
Units
- ....
.._.: _.—
._Uncontrolled_
Emissions-
(tons/year)
Emissions.
(tons/year)
;_Controlled'•:""
. —
Uncontrolled
• Basis
...... _
• (.4p:42, -
Mfg.; etc.)
_ Controlled-_�Uncont�olled
Emissions
- (tons/year)
Emissions:
(tons/year) .
PM
SOX
NOx
0.068
lb/MMBtu
AP -42
0.13
0.16
CO
0.31
Ib/MMBtu
AP -42
0.59
0.71
VOC
0.11939
lb/bbl
Eng. Est.
74.65
3.73
89.58
4.48
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical _.
Abstract
Service (CAS)
Niumber
Emission Factor
Actual Annual Emissions
Uncontrolled
•
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled`
Emissions
(pounds/year)-
Controlled
Emissions6
(pounds/year) -
Benzene
71432
0.00024
lb/bbl
Eng. Est.
303.0
15.2
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.00249
lb/bbl
Eng. Est.
3,108.6
155.4
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.
COLORADO
p�F a�ee N Patin
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 5 I
Permit Number: 1 8WE0906
AIRS ID Number: 123 / 9FCA / 004
[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 of Legally Authorized P son (not a vendor or consultant) Date
Marsha Sonderfan EHS Specialist
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 anyof these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.colorado.Qov/cdphe/apcd
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
��ICOLORADO
6I �Ra�
H._Vi 6 Ln�f�4NnM
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form1
Company Name:
HighPoint Operating Corporation
Source Name:
Critter Creek 24-1 Production Facility
Emissions Source AIRS ID2:
123-9FCA
Wells Serviced by this Storage Tank or Tank Batter (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05-123-44763
Critter Creek 247-2412H
■
05-123-44765
Critter Creek 248-2412H
•
05-123-44849
Critter Creek 295-2425H
■
05-123-44851
Critter Creek 296-2425H
■
05-123-42530
Critter Creek 575-2425H
•
05-123-42525
Critter Creek 576-2412H
D
05-123-46700
Critter Creek 210-1411H
•
05-123-46701
Critter Creek 220-1411H
•
05-123-46702
Critter Creek 230-1411H
•
05-123-46704
Critter Creek 510-1411H
•
05-123-46703
Critter Creek 530-1411H
•
05-123-46853
Critter Creek 240-1411H
III
05-123-46842
Critter Creek 250-1411H
II
05-123-46845
Critter Creek 260-1411H
•
05-123-46848
Critter Creek 540-1411H
•
•
•
•
•
•
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly reported source that has not been assigned an AIRS ID by the APCD, enter
NA
Form APCD-212
Form APCD-212 E&P Storage Tank APEN Addendum-Ver. 7-29-2014
Hello