HomeMy WebLinkAbout20194067.tiffCOLORADO
Department of Public
Health Et Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
August 28, 2019
Dear Sir or Madam:
RECEIVED
SEP 0 3 2019
WELD COUNTY
COMMISSIONERS
On August 29, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for
HighPoint Operating Company - Lion Creek 23 NWNW Pad. 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 pertnd. Please send any comment regarding this public notice to
the address below.
Colorado Dept_ of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
P0blic. Rev;
o`)/t(ot t9
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
c,c.%. Pt_cTP), EA-tcK),CGCJm)
PwCM(€RIcl-trct.$)
0•1/ IS/19
2019-4067
a
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: HighPoint Operating Company - Lion Creek 23 NWNW Pad - Weld County
Notice Period Begins: August 29, 2019
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: HighPoint Operating Company
Facility: Lion Creek 23 NWNW Pad
Well Production Facility
NWNW SEC 23 T11 N R64W
Weld County
The proposed project or activity is as follows: Crude oil tank Et hydrocarbon liquid loadout
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0237 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:
Timothy Sharp
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
(COLORADO
DCplm ant •t pnbUc
Hatith & Snvlronmtnt
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Timothy Sharp
394372
03.06.2019 & 05.16.2019
05.13.2019
Section 01 - Facility Information
Company Name: HighPoint Operating Corporation
County AIRS ID: 123
Quadrant
Section
Township
Range
NWNW
`-,
1IN
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
A000
Lion Creek 23 NWNW Pad
NWNW quadrant of Section 23, Township 11N, Range 64W
Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? 1 1 Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
No
Particulate Matter (PM) I I Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Crude Oil Tank
Crude TKs
1911V UJL3 i
Perm t initial
issuance
Liquid Loading
Yes
19WE0238
'erm t Initial
Issuance
Section 03 - Description of Project
Equipment at a well production facility. Synthetic minor to PSD for VOC
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx
Is this stationary source a major source?
If yes, explain what programs and which pollutants her€ SO2 NOx
Prevention of Significant Deterioration (PSD)
CO
VOC PM2.5 _ PM10 TSP
J
•
HAPs
CO VOC PM2.S PM10 TSP HAPs
D El
Colorado Air Permitting Project
Title V Operating Permits (OP)
Non Attainment New Source Review (NAN5R)
l
r-
° 9 °B Q OO °
(
1
1
Crude Oil Storage Tank(s) Emissions Inventory
002 Crude Oil Tank
Facility AIRs ID:
123
County
A000
Plant
002
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
4x340bhi Crude Oil Storage Tanks
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Throughput =
316,787 Barrels (bbl) per year
Actual Crude Oil Throughput While Emissions Controls Operating =
316787
Requested Permit Limit Throughput =
380,145 Barrels (bbl) per year
Requested Monthly Throughput =
32286 Barrels (bbl; per month
Potential to Emit (PTE) Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced =
380,144 Barrels (bbl) per year
Btu/scf
scf/bbl
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
Will this storage tank emit flash emissions?
29,473 MMBTU per year
29,473 MMBTU per year
34,588 MMBTU per year
Emission Factors
Crude Oil Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ib/bbl) (Ib/bbl)
(Crude Oil
Throughput)
(Crude Oil
Throughput)
VOC
2.. ,74
1 p
0.14
�
• .vl�_p t i;. ;FMS r r. Yl Y`Z -4B> ';..
Benzene
0.009
0.000
Toluene
0.007
0.000
Ethylbenzene
0.001
0.000
Xylene
0.002
0.000
n -Hexane
0.069
0.003
224 TMP
0.000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Crude Oil
Throughput)
PM10
0.0000
AP -42, Chapter 1.3,5 tudtistriel Flares (NiOx)
AAP- V Chapter 13.5 industrial Flares (CO)
PM2.5
0.0000
NOx
0.0680
0.0034
CO
0.3100
0.0155
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
520.5
433.8
21.7
520.5
26.0
4421
0.0
0.0
0.0
0.0
0.0
0
0.0 '
0.0
0.0
0.0
0.0
0
NOx
1.2
1.0
1.0
1.0
1.0
170
CO
5.4
4.6
4.6
4.6
4.6
776
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
3459
2883
144
3459
173
2737
2281
114
2737
137
380
317
16
380
19
684
570
29
684
34
26382
21985
1099
26382
1319
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
316,787
Regulation 3, Parts A,B
Source requires a permit
Regulation 7, Section XVII.B, C._, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart OOOO
Storage Tank is not subject to NSPS OOOO
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability w Drksheet for detailed analysis)
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K:\PA\2019\19W E0237.19W E0238.CP1
Crude Oil Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the sta:e default emissions factors to estimate emissions? No
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the
facility being permitted?: s
If no, the permit will contain al "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? No
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
Yes
Section 08 - Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
002
Process #
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons crude oil throughput
PM2.5 0.00 0 lb/1,000 gallons crude oil throughput
NOx 0.13 0 lb/1,000 gallons crude oil throughput
VOC 65.2 95 lb/1,00C) gallons crude oil throughput
CO 0.57 0 lb/1,000 gallons crude oil throughput
Benzene 0.22 95 lb/1,000 gallons crude oil throughput
Toluene 0.17 95 lb/1,00C gallons crude oil throughput
Ethylbenzene 0.02 95 lb/1,00C gallons crude oil throughput
Xylene 0.04 95 lb/1,00C gallons crude oil throughput
n -Hexane 1.65 95 lb/1,00C gallons crude oil throughput
224 TMP 0.00 95 lb/1,00C gallons crude oil throughput
4 of 8 K:\PA\2019\19WE0237.19WE0238.CP1
Crude Oil Storage Tank Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
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
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 facility2, natural gas compressor station3 or natural gas processing plant?
3. Is this crude oil storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions4 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 definec in 60.111b?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23; 198.4?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
S. Does the storage vessel store a "volatile organic liquid (VOL)"5 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 pressures 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 pressure6 less than 15.0 kPa(60.110b(b))?
Source Req
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Source Req
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Storage Tar
Storage Tank is not subject to NSFS Kb
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 0000, 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 emissions2 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?
Yes
Storage Tank is not subject to NSPS 0000
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids2 (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 major' 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"s per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
No
Storage Tank is not subject to MACT HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§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." and "can." is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controPing 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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Storage Tar
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Storage Tar
Hydrocarbon Loadout Emissions Inventory
003 Liquid Loading
Facility AIRs ID:
123
County
A000
Plant
003
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Yes
100.0
9.5
Requested Overall VOC & HAP Control Efficiency %: 95.00
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
316,787 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
.316..78 7 Barrels (bbl) per year
Requested Permit Limit Throughput = 380,145 Barrels (bbl) per year
Requested Monthly Throughput =
32236
Barrels (bhl) per month
Potential to Emit (PTE) Volume Loaded =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
380,144 Barrel's (bbl) per year
232S
Btu/scf
-, scf year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
Loading Loss Equation
L = 12.46*S*P*M/T
575 MMBTU per year
690 MMBTU per year
690 MMBTU per year
The stabilized hydrocarbon liquid sample is valid for developing site specific emissions factors.
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
•.... :.._
P
True Vapor Pressure
3.356
psia
M
Molecular Weight of Vapors
68
Ib/Ib-mol
T
Liquid Temperature
512.1
Rankine
L
Loading Losses
3.331412515
lb/1000 gallons
0.139919328 lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0
lb/bbl
Toluene
0
Ib/bbl
Ethylbenzene
0
Ib/bbl
Xylene
0
Ib/bbl
n -Hexane
0.00239
Ib/bbl
224 IMP
0
Ib/bbl
Emission Factors
Hydrocarbon Loadout
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Volume Loaded)
(Volume
Loaded)
VOC
1.40E-01
7.00E-03
. Specific - AP -42: Chapter 5.2,Equalir:tn I
.
., -cquation 1
Benzene
0.00E+00
0.00E+00
Toluene
0.00E+00
0.00E+00
Ethylbenzene
0.00E+00
0.00E+00
Xylene
0.00E+00
0.00E+00
n -Hexane
2.39E-03
1.20E-04
224 TMP
0.00E+00
0.00E+00
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu)
(Ib/bbl)
(waste heat combusted)
(Volume
Loaded)
PM 10
0.00E+00
AP -42 Chapter 13.5 fndustnai I ..
tP-42 Chapter .13,5 industrial Ftares (
PM2.5
0.00E+00
SOx
0.00E+00
NOx
0.0680
1.23E-04
CO
0.3100
5.63E-04
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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)
PM 10
PM2.5
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
SOx
0.00
0.00
0.00
0.00
0.00
0
NOx
0.02
0.02
0.02
0.02
0.02
4
VOC
26.59
22.16
1.11
26.59
1.33
226
CO
0.11
0.09
0.09
0.11
0.11
18
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Benzene
0
0
0
0
0
Toluene
0
0
0
0
0
Ethylbenzene
0
0
0
0
0
Xylene
0
0
0
0
0
n -Hexane
909
757
38
909
45
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
RACT - Regulation 3, Part B, Section III.D.2.a
Site is in attainment and not subject to RACT
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device? • . _ Nom.
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
:z r..
=-
T
Y.....x_3r.=
Atari
ti'aY.aCll
x'I44Ne,�iir<^ li U` Ei' {i'_—'ita'k:r•..`.•i�i'w:,�a.: c x�e..
..., .J at..Y�! ..E... Ot>t ..L ��'M )N
•• '{I E In ..0 I' x x C
e..n.
x
•'[Y :. L II �^ :IS. n JL � F'`i:CU..+a..w.vmay.+.v.w..
.-cz. a ii
.L... ��g'j'iL
�T]IJi:n:.1{• ... �.
L-11•HiiwI
>i Y/
�V.JZ'•XLL'�'Y > f
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
003
Process #
01
11 ,G n 3illugxi aJ II'it ,Pr nna �t �{III v f1 ,, I 1 .r
i G. ,ti' 11: x[•n x xyx[ji;;>2 n 111 r v ,i
G a u.._u^x18-a....I. gl
Y 1-Y n .IIY--Y .7T.•9"a^^..., 111 '1 t 11 .:,
11 �^ 3 Y Y ?'C N" [' 3])l 1 1 1
'Si {I 1, [ Ir X X% �n .x n 1 1
I ,
1•S. x....a.J h F .%.Y.. .. Y..v.. x. b. Y.I I. ... vY..f....Y e
I "1 ,I : 1
• n
n'..•I I•
!, t , liila' K a a u tr fl .,1 x sn> x •K r n r .il{tx L> u Y
yy
pit i7,lY�.i•Il_ {n , ->+1-1 R�rrx .x ar• w a ys, r .e J[ NCY u ....:, r •
L..
- •
] > I L' II a •t. 1 1IA'.Y`
A --x % 1 n xl n'h
... .. i ur: Y ^ Ihl Lp..i
:.
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (S=0.6)
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Uncontrclled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.00 0 lb/1,000 gallons transferred
V0C 3.3 95 lb/1,000 gallons transferred
CO 0.01 0 lb/1,000 gallons transferred
Benzene 0.00 95 lb/1,000 gallons transferred
Toluene 0.00 9S lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n -Hexane 0.06 95 Ib/1,000 gallons transferred
224 TMP 0.00 95 Ib/1,000 gallons transferred
7 of 8 K:\PA\2019\19WE0237.19WE0238.CP1
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.I)?
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 II.D.1.l)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.2)?
You have indicated that source is in the Attainment Area
7. RACT - Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section III.D.2.a)?
Site is in attainment and not subject to RACT
Disclaimer
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 uncer 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 loadou
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0237 Issuance: 1
HighPoint Operating Corporation
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Lion Creek 23 NWNW Pad
123/A000
NWNW SEC 23 T11 N R64W
Weld County
Well Production Facility
Equipment or activity, subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment` Description
Emissions Control
Description
Crude TKs
002
Four (4) 840 barrel fixed roof storage
vessels used to store crude oil
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1." and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
compliance as required by this permit may be obtained online at www.colorado.Rov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
Crude TKs
002
--
---
26.1
5.4
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
Crude TKs
002
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
Crude TKs
002
Crude Oil
Throughput
380,145 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughputlimits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep'a compliance record on ste or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
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:
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation. Number 7, Section XVII.C.1. The owner or operator must install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source must follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available
to the Division upon request. This control requirement must be met within 90 days of the date
that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING £t MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operatormust follow the most recent operating and
maintenance (0&tM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ; ongoing basis with the requirements of this permit. ! Revisions to
the 0&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
16. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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; 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.
19. The requirements of Colorado Regulation No. 3, Part D must 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
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21.. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not 'applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed' denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), ! -122 (civil
penalties), =122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to HighPoint Operating Corporation
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working', day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https: / /www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable airpollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)'
002
Benzene
71432
2,892
145
Toluene
108883
2,273
114
Ethylbenzene
100414
309
15
Xylenes
1330207
579
29
n -Hexane
110543
21,986
1100
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
0.068 lb/MMBtu
CDPHE
CO
0.310 lb/MMBtu
CDPHE
V0C
2.74
Source
71432
Benzene
0.0091
Source
108883
Toluene
0.0072
Source
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
100414
Ethylbenzene
0.0010
Source
1330207
Xylene
' 0.0018
Source
110543
n -Hexane
0.0694
Source
Note: The controlled emissions factors for this point are based on a 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 must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Operating Permit
Synthetic Minor Source of: VOC, HAP
PSD
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix I
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
Page 8 of 9
MACT
COLORADO
Air Pollution Control Division
Department of Public Heatth t Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
COLORADO
Air Pollution Control Division
Department of Public Heath b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0238
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
HighPoint Operating Corporation
Lion Creek 23 NWNW Pad
123/A000
NWNW SEC 23 T11 N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point -
Equipment Description
Emissions Control
Description
003 -
Truck
submerged
loadout of crude oil by
fill
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution, Prevention and Control Act'(C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of
the latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/cdphe/air/manage-permit. Failure to
notify the Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Publac Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4. )
4. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must not exceed the following limitations. (Reference: Regulation
Number 3, Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
pM2.5'NOX
VOC
CO
003
---
---
1.4
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air pollutants must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
003
Enclosed Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Reference: Regulation Number 3, Part
B, II.A.4)
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
003
Crude Oil Loaded380,145
barrels
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on ste or at a local field office with site responsibility, for Division
review.
9. Condensate loading to truck tanks must be conducted by submerged fill. (Reference. Regulation
Number 3, Part, B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases must
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30%
opacity for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. All hydrocarbon liquid loading operations, regardless of size, must be designed, operated and
maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the
maximum extent practicable.
13. The owner or operator must follow loading procedures that minimize the leakage of VOCs to
the atmosphere including, but not limited to (Reference: Regulation Number 3, Part B, III.E):
a. The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loading and unloading. The inspections must occur at least monthly.
Each inspection must be documented in a log available to the Division on request.
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
b. All compartment hatches at the facility (including thief hatches) must be closed and
latched at all times when loading operations are not active, except for periods of
maintenance, gauging, or safety of personnel and equipment.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch
covers must be weighted and properly seated.
d. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs must be set to release at a pressure that will ensure flashing, working
and breathing losses are not vented through the PRD under normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of status,
a description of any problems found, and their resolution.
14. For this controlled loading operation, the owner or operator must follow loading procedures
that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference:
Regulation Number 3, Part B, III.E):
Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
Include devices to prevent the release of vapor from vapor recovery hoses not in use.
Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless
the vapor collection equipment is in use.
Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
OPERATING Et MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must 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 your OEtM 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
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
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.
19. The requirements of Colorado Regulation Number 3, Part D must 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
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25 -7 -
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specificallystated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution'
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Timothy Sharp
Permit Engineer
Permit History
Issuance
Date
Description
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Issuance 1
This Issuance
Issued to HighPoint Operating Corporation
Page 7 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See::https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
n -Hexane
110543
758
38
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
VOC
0.13983
Site Specific
n -Hexane
110543
0.00239
Site Specific
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) = 3.356 psia
M (vapor molecular weight) = 68 lb/lb-mot
T (temperature of liquid loaded) = 512 °R
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Rabic Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated
by multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
PSD
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix t
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
&,?,o, - / I' ') '4dk9k4..,.% /}+ke-/ - S. 16.
0 C J,`q
Crude Oil Storage Tank(s) APEN
Form APCD-210 so„, °
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the
General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A
list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division
(APCD) website at: www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
l9WE'z37
AIRS ID 123 / A000 / p Oz.
Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
Site Location:
HighPoint Operating Corporation
Lion Creek 23 NWNW Pad
Site Location
NWNW Sec. 23, T11 N, R64W County: Weld
Mailing Address:
(Include Zip Code) 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.
35436E
COLORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 1 I AvKeit4s arQ" m,
Permit Number:
AIRS ID Number: 123 / A000/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
O Request coverage under General Permit GP08
If General Permit coverage is requested, the General.Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name3
❑ 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 Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Four (4) 840 bbl Crude Oil Tanks
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 12/6/2018
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
❑✓ Exploration Et Production (EftP) site
weeks/year
O Midstream or Downstream (non EftP) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
•
n
Are Flash Emissions anticipated from these storage tanks?
p
Yes
•
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)•
805 series rules? If so, submit Form APCD-105.
Yes
No
D
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
ri
■
COLORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
O Upward
❑ Horizontal
Permit Number:
AIRS ID Number: 123 /A000/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bb(/year)
Requested Annual Permit Limits
(bbl/year)
Crude Oil Throughput:
316,787
380,145
From what year is the actual annual amount?
2018/2019
Average API gravity of sales oil: 35.1 degrees
0 Internal floating roof
Tank design: 0 Fixed roof
RVP of sales oil: 7.1
0 External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in :,
Storage Tank (month/year)
Date of First
Production
(month/year)
Crude TKs
4
3,360
11/2018
12/2018
Wells Serviced by this Storage Tank or Tank Battery6 (EaP Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 47385
Lion Creek 23-0164B
a
05
- 123
- 47386
Lion Creek 23-0263D
0
05
- 123
- 47399
Lion Creek 23-0362B
l9
-
-
■
-
-
■
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.912756 / -104.517319
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)
0 Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): 48
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
Interior stack depth
(inches):
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
3 'AV
COLORADO
ctaaawm
Hc:.NE h 6ntIteNnmt
Permit Number:
AIRS ID Number: 123 / A000 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
0 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: Make/Model:
Requested Contra( Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑✓ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: 2.83
Type: ECD
MMBtu/hr
Make/Model: LEED
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: N/A
Waste Gas Heat Content: 2 328 Btu/scf
Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: 0.45 MMBtu/hr
O Closed Loop System
Description of the closed loop system:
O Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (E&tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —32 psig
Describe the separation process between the well and the storage tanks: Crude oil from the 3 -phase
inlet separators is routed to the heated flash gas separator (oil polisher) and then to the storage tanks.
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
COLORADO
4 I mIA45trv1[CMrnI
Permit Number:
AIRS ID Number: 123 /A000/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions) `.
VOC
ECD
95%
NOx
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? 2018/2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor?
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions•
(tons/year)
Uncontrolled
Em(ssions"
(tons/year)
Controlled
Emissions
(tons/year)-
VOC
2.0061
lb/bbl
Eng. Est.
317.75
15.89
381.29
19.06
NOx
0.068
Ib/MMBtu
AP -42
0.72
0.72
0.84
0.84
CO
0.31
Ib/MMBtu
AP -42
3.30
3.30
3.84
3.84
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (Cps)
( �
Number
Emission Factor? ,_
Actual. Annual. Emissions.,:.,w.r
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions.
ass
(pounds/year)
Benzene
71432
0.0039
lb/bbl
Eng. Est.
1,226
61
Toluene
108883
0.0027
lb/bbl
Eng. Est.
846
42
Ethylbenzene
100414
Xylene
1330207
0.001
lb/bbl
Eng. Est.
302
15
n -Hexane
110543
0.0343
lb/bbl
Eng. Est.
10,873
544
2,2,4-
Trimethylpentane
540841
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
. Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 5
COLORADO
eepaanenemAu,:m
HeaiM@Envimemol
Permit Number:
AIRS ID Number: 123 /A000/
[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.
c -Max -19
Signature of Legally Authorized Person (nat 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
12 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: / /www.colorado.Rov/cdphe/aocd
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
COLORADO
6 I AV hitaut
RMn
Crude Oil Storage Tank(s) APEN
Form APCD-210
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
condensate storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the
General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A
list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division
(APCD) website at: www.colorado.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.
Permit Number:
AIRS ID 123 / A000 / 002
I "I WE 2 51 Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Lion Creek 23 NWNW Pad
Site Location: NWNW Sec. 23, T11 N, R64W
Mailing Address:
(Include Zip Code) 555 17th Street, Suite 3700
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
Marsha Sonderfan
303-312-8542
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.
389601
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
COLORADO
1 I ®
Ht20#bSP.NRmn,
Permit Number:
AIRS ID Number: 123 / A000 / 002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
❑ Request coverage under General Permit GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR -
▪ MODIFICATION to existing permit (check each box below that applies)
o Change in equipment ❑ Change company name'
o Change permit limit 0 Transfer of ownership4 0 Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Four (4) 840 bbl Crude Oil Tanks
Company equipment Identification No. (optional):
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is: 12/6/2018
Normal Hours of Source Operation: 24 hours/day 7 days/week 52
Storage tank(s) located at:
❑✓ Exploration Et Production (E&P) site
weeks/year
0 Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
•
p
Are Flash Emissions anticipated from these storage tanks?
p
Yes
■
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
•
BI
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
O
■
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
pp (COLORADO
2 I Aar I mp
HeSJ�6F. alronmmt
Permit Number:
AIRS ID Number: 123 / A000 / 002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
ACt(latAffifaarWoViit
{bb /y ar
Requested Annual Permit Limits
.. _ (bl/year)) `,
Crude Oil -Throughput:
316,787
380,145
From what year is the actual annual amount?
2018/2019
Average API gravity of sales oil: 35.1 degrees
O Internal floating roof
Tank design: ❑✓ Fixed roof
RVP of sales oil: 7.1
O External floating roof
e
Storage
ank ID
#oft quid Mangold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
{bbl) ;;
Installation,;, ate;ofMost
ate- of F rst„
ry�roduction tlti
(month/year
Rec n Storages esselliinn
Storage TankA(month/year)
Crude TKs
4
3,360
11/2018
12/2018
Wells Serviced bythis Storage Tank Pr.,- ank BatteryAE, kitSites Only, 4. .
AM' .APIber
Nameof.Well...,
.Newly Reported WA1
05 - 123 - 47385
Lion Creek 23-01648
12
05 - 123 - 47386
Lion Creek 23-0263D
l7
05 - 123 - 47399
Lion Creek 23-0362B
SI
- -
■
_ -
■
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EItP 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
s apt�i CoordIna
attudeILongitude or UT
40.912756 / -104.517319
Operator Stack'
ID No u .
Discharge Height Above
Ground Level (feet)_
Temp
('F).' .....
Flow Rate
(ACFM) __ �.
Velocity
_. (ft/see).. ..
ECD
TBD
TBD
TBD
TBD
Indicate the direction of the stack outlet: (check one)
❑✓ Upward O Downward
O Horizontal O Other (describe):
Indicate the stack opening and size: (check one)
11 Circular Interior stack diameter (inches):
o Square/rectangle Interior stack width (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
48
Interior stack depth
(inches):
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 3
COLORADO
Depaarnera oteuntie
2l4244h4PWIT ttene
Permit Number:
AIRS ID Number: 123 / A000 / 002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
% •
❑ Combustion
Device:
Pollutants Controlled:
Rating:
VOC, HAPs
3.95
Type: ECD
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: N/A
MMBtu/hr
hr
Make/Model: LEED
95
98
%
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating:
2,168
0.45
Btu/scf
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 (EEP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -88 psig
Describe the separation process between the well and the storage tanks: Crude oil from the 3 -phase
inlet separators is routed to the heated flash gas separator (oil polisher) and then to the storage tanks.
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018
COLORDO
4 I ,�►• Ito,A
8.0000 €000000000
Permit Number:
AIRS ID Number: 123 / A000/ 002
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction ):
Pollutant
4 • ,. " �.
r `
Description of Control Methods)
_ ..�, .. .,
Overall Requested Control
Efficiency
.mss:(%,reduction in emissions), . .
VOC
ECD
95%
NOx
CO
HAPs
ECD
95%
Other:
From what year is the following reported actual annual emissions data? 2018/2019
feria .Pollutant Emissions Inventory
Pollutants
Emission Factor
Actual Annual
- W _
Emissions,
M g,t
lie uested Annual Permit
sb
Emission L7mit(s)
Uncontrolled
Basis
U
..
Source
rA 42t
7 g, etc.)
Uncontrolled
Emissions
(tons/year):
Controlled
e
Emissions,'
- (tons/year)
Uncontrolled
`Emission
(#ans/year
Controlled
ns
Emissions
,'ltonslyear)
VOC
2.74
lb/bbl
Eng. Est
433.77
21.69
520.53
26.03
NOx
0.068
Ib/MMBtu
AP -42
1.00
1.00
1.18
1.18
CO
0.31
lb/MMBtu
AP -42
4.57
4.57
5.36
5.36
on-Cnteria,Reportable
Pollutant Emissions, Inventory
Chemical Name
Chemical
Emission Factorl,
ua1 Annual Emissions
Abstra g
= -
Sernce (CAS
Numfier
Uncontrolled
�, Basis
.. .
Units ,
,
Sou�rce�
(AP 42,E
Mfg .,',,P tc.)._
t e
Unco scions d
Emissions
�
t (pounds/ r)ri
Contro led
En fissions s
.,ate �..
,.. (pou nds/year).
Benzene
71432
0.0091
lb/bbl
Eng. Est
2,892
145
Toluene
108883
0.0072
lb/bbl
Eng. Est
2,273
114
Ethylbenzene
100414
0.0010
lb/bbl
Eng. Est
309
15
Xylene
1330207
0.0018
lb/bbl
Eng. Est
579
29
n -Hexane
110543
0.0694
lb/bbl
Eng. Est
21,986
1,100
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.
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 5 I
COLORADO
Ce,auanentat PuL:ia
Ift—A0 .Invirmrg 4t
Permit Number:
AIRS ID Number: 123 /A000/ 002
[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.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Brandon Thomas
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 $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.$ov/cdphe/apcd
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 7/2018 6 ► AV
COLORADO
DepoossnentofPudm
Hydrocarbon Liquid Loading AP
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.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: 190e e C31-33 AIRS ID Number: 123 / A000 /Oo)
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name1:
Site Name:
Site Location:
HighPoint Operating Corporation
Lion Creek 23 NWNW Pad
NWNW Sec. 23, T11 N, R64W
Mailing Address:
(Include Zip Code) 1099 18th St. Suite 2300
Denver, CO 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Marsha Sonderfan
Phone Number: 303-312-8524
E -Mail Address2: CDPHE_Corr@hpres.com
I Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
394369
1I AV
COLORADO
Ie,m.reemdPublic
Hea4Ve§klaaarpnmfl!!
Permit Number: AIRS ID Number: 123 / A000 I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under construction permit
0 Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership4 0 Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
ID Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: 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: 12/6/2018
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
■
N
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
N
Does this source load gasoline into transport vehicles?
Yes
No
■
N
Is this source located at an oil and gas exploration and production site?
Yes
No
N
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
N
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
•
p
Does this source submerge fill less than 16308 bbt of condensate per year?
Yes
No
■
N
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
COLORADO
21
Deonip itg I
� Heet!R6 Envlrcnm.4ro!
Permit Number:
AIRS ID Number: 123 / A000 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑✓ Crude Oil 0 Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
380,145
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")
316,787
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
0.6
Average temperature of
bulk liquid loading:
52. A G
J •-t�7
°F
True Vapor Pressure:
3.356
Psia ® 60 °F
Molecular weight of
displaced vapors:
Q
68
lb/lb-mot
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 3 1
COLORADO
DeparementolPubile
NYY tiepins t Envimnmen4
Permit Number:
AIRS ID Number: 123 / A000 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.912756 / -104.517319
Operator x
�
Stack 1D X10
Discha a Hei it
round el
Term
{
.
l
t
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)
❑✓ Circular
❑ Other (describe):
0 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.
0 Loading occurs using a vapor balance system:
Requested Control Efficiency: %
❑ Combustion
Device:
Used for control of: VOC, HAPs
Rating: 0.17
Type: ECD
MMBtu/hr
Make/Model:
LEED
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: N/A °F Waste Gas Heat Content: 2,328 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.45 MMBtu/hr
0 Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 4
COLORADO
U°p°rtma. el Palle
Het!* DIVilN CP.!
Permit Number:
AIRS ID Number: 123 /A000 /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 7 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
p
Overall Requested
Control Efficiency
(x reduction in emissions)
PM
50,E
NO,
CO
VOC
ECD
95%
HAPs
ECD
95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 2018/2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOX
NO,
0.068
Ib/MMBtu
AP -42
0.04
0.04
0.05
0.05
CO
0.31
Ib/MMBtu
AP -42
0.19
0.19
0.23
0.23
VOC
0.13983
lb/bbl
AP -42
22.15
1.11
26.58
1.33
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions6
(pounds/year)
Benzene
71432
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.00239
lb/bbl
Eng. Est.
758
38
2,2,4-
Trimethylpentane
540841
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018
5I AY
COLORADO
nmmwwnm
MA%4€ATIMnmml
Permit Number:
AIRS ID Number: 123 / A000 /
[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 (not a vendor or consultant) Date
Marsha Sonderfan
EHS Specialist
Name (print) Title
Check the appropriate box to request a copy of the:
E✓ Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 7/2018 6 I
COLORADO
De}u trnentW A};k
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