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Home My WebLink About20181377.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 April 25, 2018 Dear Sir or Madam: RECEIVED APR 302018 WELD COUNTY COMMISSIONERS On April 26, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Fifth Creek Energy Operating Company, LLC - Critter Creek 15-2 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 period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Ft Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer ?u.bl« RvAtto ec: PLC Akm.lrP), FIL(Tr), ps-b?-l8 ink1 CER.! RiInk( K) 01.1-30-1 2018-1377 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Fifth Creek Energy Operating Company, LLC - Critter Creek 15-2 Pad - Weld County Notice Period Begins: April 26, 2018 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: Fifth Creek Energy Operating Company, LLC Facility: Critter Creek 15-2 Pad Oil Et Gas Production facility SWSE Section 15, T11 N, R63W Weld County The proposed project or activity is as follows: Existing well production facility adding three (3) new wells and associated equipment. 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 17WE1232 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. Any such comment must be submitted in writing to the following addressee: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us COLORADO 1 I iNagantsam,rd b Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package #: Received Date: Review Start Date: Bradley Eades.. 371994,,, 11/29/2017 2/21/2018 „... Section 01- Facility Information Company Name: Fifth Creek Energy Operating Company, LLC County AIRS ID: 123 Plant AIRS ID: 5919 Facility Name: Critter _ Critter Creek 9-15) --- .Creek '� 5-2 Pad Physical Address/Locatio SWSE quadrant of Section 15, Township 1119, Ravage 63W, in Weld County, COloredo Type of Facility: Expjoyetipn & Prnduetjon Well Pad /nN.,,,, What industry segment? O#8(lNatiaa Ga;s ractron,a,Processmg Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? Don Monoxide (CO) Section 02 - Emissions Units In Permit Application Weld Section Township Range SW5E 15 7ST1 63 Diculate Matter (PM) Eine (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit 8 Issuance 8 Self Cert Required? Action Engineering Remarks 011 CrudeOilTante Yes 17W812232 1 Yes Permit Initial Issuance Section 03 - Description of Project Existing well production facility consisting alone (1) well. This permit is for a new tank battery to store crude oil from three (3) new wells. Existing storage tanks (Point 001) continue to be permitted under GPDB while an individual permit will be issued for the new storage tanks (Point (111). Fifith Creek Energy Operating Company, LLC has become HighPoint Resources Corporation since the submittal of this application. However, th€sfactltiy was included in a multi -facility transfer of ownership application currently being processed. As such, this permit will be issued to Fifth Creek. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synttretit Minor PeceE Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? f oaf 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 IPSO) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? If yes, explain what programs and which pollutants here SO2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP ❑ ❑ HAPs ❑ ❑ Crude Oil Storage Tank(s) Emissions Inventory Section al -Administrative Information (Facility AIRS ID: 123 County Plan .1017 Pom Section 02 - Equipment Description Details Detailed Emissions Unit Description: Five (5)840 bbl cr Emission Control Device(;nd6sod Flare; Description: Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput = Barrels (bbl) per year Actual Crude Oil Throughput While Emissions Controls Operating = Barrels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Hest content of waste gas= 2X7'4:5' Btu/scf Volume of waste gas emitted per BBL of liquid produced = 10.5377! scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 15,263 MMBTU per year 15,263 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 15,263 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Crude Oil Throughput) 0.8699:: 00016 0.0®11:. 0.000 0.0004...... 0.0406 0.0001 (Crude Oil Throughput) 0.0435 0.0001 0.0001 4.81E-06 0.0020 6.19E-06 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (lb/bbl) 0.0075:..... 0.13801 0.2755 (Crude Oil Throughput) 0.0002 0.0002 0.0033 0.0066 Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Units Uncontrolled Controlled (tons/year) (tons/year) VOC PMID PM2.5 NOx CO 277.0 277.0 13.8 277,0 13.85 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 1.1 1.1 1.1 1.1 1.05 2.1 2.1 2.1 2.1 2.10 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 990 990 49 990 49 675 675 34 675 34 61 61 3 61 3 237 237 12 237 12 25877 25877 1294 25877 1294 79 79 4 79 4 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Storage tank Is subject to Regulation 7, Section XVII.C.2 Storage Tank is not subject to NSPS Kb Storage Tank is not subject to NSPS 0000 Storage Tank is not subject to MACT HH 0'r. 2 of 5 K:\PA\2017\17 W E1232.CP1.xlsm Crude Oil Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the z e facility being permitted? Yes If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efflciency'of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Emission factor5for ttAP5afe based. en the ProMaxlb[hfoutput and modeled throughput, and totalworkingaod linen are based on the VOCrAteryo5iUot}t'r.gaethe pressurized tigatdsome .5 Since the Dials ce does not have a prescribedinel and acceptable estimate; AIRS Point # 011 Process # 5CC Code 01 fnultlplid by, the MAP,foactden tnthe w&B"vapors_E#A ticuleting ItAP emisslerts fromwoektng,and breetfdng- Section 09 - Inventory 5CC Coding and Emissions Factors 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 0.08 0 lb/1,000 gallons crude oil throughput VOC 20.7 95 lb/1,000 gallons crude oil throughput CO 0.16 0 lb/1,000 gallons crude oil throughput Benzene 0.04 95 lb/1,000 gallons crude oil throughput Toluene 0.03 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.00 95 lb/1,000 gallons crude oil throughput Xylene 0.01 95 lb/1,000 gallons crude oil throughput n -Hexane 0.97 95 lb/1,000 gallons crude oil throughput 224 TMP 0.00 95 lb/1,000 gallons crude oil throughput 3 of 5 K:\PA\2017\17 W E 1232. C P 1.xism Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 'Source is in the Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 Is yes, is the crude oil throughput 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 ll.D.3)? Source requires a permit NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greaterthan 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 throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greaterthan 2 TPY, NOx greater than 5 TPY or CO emissions greaterthan 5 TPY (Regulation 3, Part B, Section II.D.2)? You have indicated that source is iv the Attainment Area • Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station'or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? '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. 'Storage tank is subject to i;egulati0n 7, Secti0n XVII.C2 Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment NAl! Yes;: No Yes Nj 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 (m) ["'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 m' ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.1116? 3. Was this condensate storagetank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess. of 204.9 kPa ["29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M' (-472 BBL] but less than 151 m' (^950 BBL] and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))? Storage Tank is not subject to 5565 Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements 460.1166 - 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 emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"' per 60.5430? Storage Tank is not subject to t4SPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC 460.5413 - Testing and Procedures 460.5395(g) - Notification, Reporting and Record keeping Requirements 460.5416(c) - Cover and Closed Vent System Monitoring Requirements 460.5417 -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 MAR HH, Oil and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (83.760)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"" in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CPR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not subject to MALT HH Subpart A, General provisions per 463.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774 - Record keeping §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 controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes Yes CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE1232 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 Fifth Creek Energy Operating Company, LLC Critter Creek 15-2 Pad 123/8919 SWSE SEC 15 T11 N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Crude Oil Tanks 011 Five (5) 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/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 'COLORADO Air Pollution Control Division .taetIne tot tub si otft s Errinment Page 1 of 8 3. r or aerator of the source for which this permit was issued: n/rn.x ification or operation of this source within 18 months to `` is .nce of is construction permit or the date on which such vity as heduled o commence as set forth in the permit application ssociat it i pe l discon l ues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator.shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO Crude Oil Tanks 011 --- --- 13.9 2.1 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 shalt not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled Crude Oil Tanks 011 Enclosed Flare VOC and HAP COLORADO it Pollution Control Division er'-u 5t of 1 ier3^i. 6 E+ivi! ,rriert Page 2 of 8 8. This - urn sill be." «d to 3h= folio <;ng maximum processing rates as listed below. Monthly l pry essi rates s ll be maintained by the owner or operator and made ablhioni=pctionrequest. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit - Crude Oil Tanks 011 Crude Oil Throughput 636,800 barrels The owner or operator shall monitor monthly process rates based on the calendar month. During the first twelve (12) months of operation, compliance with both the monthly and annual throughput limitations is required. After the first twelve (12) months of operation, compliance with only the annual limitation is required. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 12. 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 shall 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 shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. ,COLORADO Air Pollution Control Division rbk I3E ;h & L.vltor Page 3 of 8 OPE ANC • UIR �A., TS 14. Upon a pf the • •._ ts,, e'•wne r operator shall follow the most recent operating and Et fi pla s an. record a eping format approved by the Division, in order to ncgoin -N .is with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 15. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or 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; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, VI.B.4). [COLORADO Air Pollution Control Division men,Wt & Enviro'tme t Page 4 of 8 GENERAL TERMS AND CONDITIONS 19. This -r d an ..s..chm e re mus,<.e retained and made available for inspection upon sued to . ew owner by the APCD as provided in AQCC Regulation upon a rquest for transfer of ownership and the submittal of a e. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with ,he provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ob initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer COLORADO Air Pollution Control Division Den ritnaerd t P bVa 4e' u L, rrr6 meet Page 5 of 8 Is a e D e Description Iss nc is I ance ssued to Fifth Creek Energy Operating Company, LLC ynthetic Minor Facility COLORADO Pollution Control Division �r =Neale& & nr*aur:c Page 6 of 8 Notes Per . '''at th., a of . i aermi' issuance: e processing time for this permit. An invoice for these he permit holder shall pay the invoice within 30 days e. o pa .. , #- invoice wilt result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 011 Benzene 71432 990 49 Toluene 108883 675 34 Ethylbenzene 100414 61 3 Xylenes 1330207 237 12 n -Hexane 110543 25,877 1,294 2,2,4- Trimethylpentane 540841 79 4 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 011: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0033 0.0033 TNRCC CO 00066 0.0066 VOC 0.8699 0.0435 ProMax / EPA TANKS 71432 Benzene 0.0016 0.0001 108883 Toluene 0.0011 0.0001 110543 n -Hexane 0.0406 0.0020 Note: The controlled emissions factors for this point are based on the flare 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 COLORADO Air Pollution Control Division 73ere[ d Pubk Weah b E--,rronrrtett Page 7 of 8 A th as at 7) Th's permit fulfills the requirement control device per the Colorado applicable. 8) This facility is classified as follows: before the five-year term expires. Please refer to ne the APEN expiration date for each emissions point regarding a specific expiration date call the Division to hold a valid permit reflecting the storage tank and associated Oil and Gas Conservation Commission rule 805b(2)(A) when • Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.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 MACT 63.8980 -End Subpart NNNNN - Subpart XXXX)0C COLORADO Air Pollution Control Division p_;rticr:^:t r,.t A WeGkh n lm i*orretert Page 8 of 8 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 APEt' 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: 1'7 (A) /Z3 Z. AIRS ID Number: 123 / 8919 / 0 ) I [Leave blank unless APCD has alraady assigned a permit_ 4 and AIRS ID] Section 1 - Administrative Information Company Name': Fifth Creek Energy Operating Company, LLC Site Name: Critter Creek 15-2 Pad (fka Critter Creek 9-15) Site Location: SW SE Section 15, Township 11N, Range 63W Mailing Address: (Include Zip Code) 5251 DTC Parkway, Suite 420 Greenwood Village, CO Site Location County: Weld NAICS or SIC Code: 211111 Permit Contact: Kent Gilbert Phone Number: (303) 478-8393 E -Mail Address2: kgilbert@fifthcreekenergy.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 APCD via e-mail to the addressprovided. 371-99j AY COLORADO a E,:wa 1m°.l Permit Number: AIRS ID Number: 123 / 8919 / [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 $250 must be submitted along with the APEN filing fee. - OR - El MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ 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 It Notes: Formerly known as Critter Creek Pad 9-15. Fifth Creek Energy added three (3) new wells (Critter Creek 562-1527H, 512-1510H, and 278-1527H). 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-1O4) must be submitted. Section 3 - General Information General description of equipment and purpose: For existing sources, operation began on: five (5) 840 bbl crude oil storage tanks For new or reconstructed sources, the projected start-up date is: 8/31/2017 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 0 Exploration Et Production (EEtP) site weeks/year ❑ Midstream or Downstream (non EE&P) site Will this equipment be operated in any NAAQS nonattainment area? • Yes el No Are Flash Emissions anticipated from these storage tanks? O 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 No • Igl V Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Y Yes Form APCD-210 Crude Oil Storage Tank(s) APEN - Revision 07/2017 COLORADO 2 I ATtires YEi.vg.Im m He Permit Number: AIRS ID Number: 123 / 8919 / [Leave blank unless APCD has already assigned a permit N and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl /year) Crude Oil Throughput: 636,800 From what year is the actual annual amount? Average API gravity of sales oil: 38.2 degrees ❑ Internal floating roof Tank design: ❑� Fixed roof RVP of sales oil: ❑ 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) 5 4,200 8/2017 8/2017 Wells Serviced by this Storage Tank or Tank Battery5 (Ear' Sites On y) API Number Name of Well Newly Reported Well 05 - 123 - 42507 Critter Creek 562-1527H • 05 - 123 - 42508 Critter Creek 512-1510H MI 05 - 123 - 44711 Critter Creek 278-1527H 0 ■ 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 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) 40.916963/-104.417244 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) 25 97 0.13 Indicate the direction of the stack outlet: (check one) 0 Upward ❑ Downward El Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) 2 Circular ❑ Square/rectangle ❑ Other (describe): El Upward with obstructing raincap Interior stack diameter (inches): 48 Interior stack width (inches): Interior stack depth (inches): Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 COLORADO 3 I hrFi' mEntrc`(N�ml�n� Permit Number: AIRS ID Number: 123 / 8919 / [Leave blank unless APCD has already assigned a permit f and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: 0/0 ❑ Combustion Device: Pollutants Controlled: VOC and HAPs Rating: Type: enclosed combustor MMBtu/hr Make/Model: Leeds 48" 6 units) Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: z Yes ❑ No Pilot Burner Rating: Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (EttP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 35 psig Describe the separation process between the well and the storage tanks: The wells flow to a separator where the oil is separated out and sent to the oil storage tanks. Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 07/2017 4 I ACOLORADO l� Nparmnnt f t 1n Permit Number: AIRS ID Number: 123 / 8919/ [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 form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) V0C ECD 1 95% NOx CO HAPs ECD 95% Other: From what year is the following reported actual annual emissions data? Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/ ear y ) Controlled Emissions7 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 3-2 f lb/bbl CDPHE 589 G. t 1,018• -1110 NOx 0.138 Ib/MMBtu TECQ 0.00 X4-13 LOS CO 0.276 Ib/MMBtu TECQ 0.00 8.24..,(` Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions7 (Pounds/year) Benzene 71432 0.046.O.05I4Ib/bbl CDPHE- et`10 'q Toluene 108883 ©,QM1 (VW NMI 6.4 Sy Ethylbenzene 100414 0.0001 G) .3 Xylene 1330207 (100044 a 34 o. n -Hexane 110543 0.2456.( lb/bbl CDPHE .?S ��. pq y 2,2,4- Trimethylpentane 540841 0.0001 b�l ``'' ll (I 99 9 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 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 07/2017 AVCOLORADO Permit Number: AIRS ID Number: 123 / 8919 / 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) Kent Gilbert it /-zt 7i7 Date Vice President - Operations Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance O 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 $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: Make check payable to: https://www.colorado.gov/cdphe/apcd Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Avpv. COLORADO 6 I Hello