The URL can be used to link to this page

Browse Search

Home My WebLink About20183190.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 September 24, 2018 Dear Sir or Madam: RECEIVED OCT 012018 WELD COUNTY COMMISSIONERS On September 27, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for Cub Creek Energy, LLC - Vail 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 a 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. Hickentooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer I'v(rj lc. 02,4-u Cc : PLCTP), Ht. CJT), I O! / I Fs' Ptvf ER/CH l JYv1 (C K) ic�la��g 2018-3190 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Cub Creek Energy, LLC - Vail Pad - Weld County Notice Period Begins: September 27, 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: Cub Creek Energy, LLC Facility: Vail Pad Oil Et Gas Wellsite SWNW Sec 12 T4N R68W Weld County The proposed project or activity is as follows: Venting of separator gas to enclosed flare during sales gas pipeline downtime The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0111 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: Christian Lesniak Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 0 ADO Colorado Air Pers�nitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer. CFinst�ar�Lzsniak Package#: 37�44II : -: 3 ,,, � Received Date: ��3p18: ----i.�-�� - � Review Start Date: Sf'LH/2628 _ Section 01-Faciiity Information Company Name: Cu1�Gee�J�Ene�gy,LtG}� " Quadrant Section Township Range County AIRS ID: I2x' SLNN4U'> 12:� �N ..68:' '�� Piant AIRS ID: 9�iC ' Facility Name: l�a�pad : ; : : � " � '��`'� Physical . ... - . . - . - .- . . . � Addi'ess/Lo[ation: SWNW quadrant of Section 12,Township 4N,Range 68W County: Weld County Type of Facility: Exp7" �cw&aruduct[on yJell Pad- :: .: : :: �I Whet industry segment��,�,,,�,�aa��s�r��₹ian&Pr+�cesu�mg �f�t��y€�I�/�l"�f..,.��,`��E� Is this facfliry located in a NAAQS non-attainment area7 �� Yes,f�� If yes,for what pollutant? � car�on nono�,de�m� -- �F aarea,iate Matter�aM� Q o-�o�e�Nox�voc� Section 02-Emissions Units In Permit Application � Emissions Self Cert Engineering AIR5 Point tl Emissions Source Type Equipment Name Permit# Issuance# , Action Control? Required? Remarks . .' , �Em31�'f'itiol � {308 I � Se�ara;orUen�.rg �� IENT=* ye., ., � 18WEGiyS (. 1 `?e�'.. s�u,_c..' � �—�:------ --4-- 7 � �_�� 9 : i i [ �, . � v ', . ...... :�. : � '�. ��' : � — :' . — . `t �� '� I � — _ � Section 03-Description or"Project Scurr_e has taad�ssczs,v th,p�Ne1�.r.ss?rom o��her cornp�nFes,�nd fs requ�sting a pemrt`or sepa raYor venfrng.Saies�gas'ts cu rrenciy tied mto ptpeltae,�'u�sovi ce is rsauesiing_ #{ar ng of sales aas;i��:�_n pipehrv�s�'own.Gas to enciosed mmnus�or will be rnecered_ Section 04-Public Commerrt Requirements Is Public Comment Required? Yes: - � If yes,why? ₹teqvesi[ag.Synt#�#�e iv7inor Re}-ra�T: . , . . . . Section 0S-Ambient Air Impact Analysis Requirement � Was a quantitative modeling analysis required? �I� � If yes,for what polfutants? If yes,attach a copy of Technical Services Unit modeling results summary. �� - . Se�tion 06-Faciliry-Wide 5tationary Source Classification Is this stationary source a true minor? �'�- " >` Is this stationary source a sysithetic minor? , Yes`��. � If yes,indicate programs and which pollutants: 502 NOx � CO VOC PM2.5 PM10 TSP HAPs Preverttion of Sigrtificant Deterioration(PSD) � Title V Operating Permits(QP) J � � Non-Attainment New Source Review(NANSR) ��. Is this stationary source a major source? If yes,explain what programs and which pollutants hen 502 NOx� �CO VO��C-ry99 PM2.5 PM10 TSP HAPs Prevention of Significant De#erioration(PSD) 8 � � � � � ❑ ❑ Title V Opereting Permits(OP) Non-Adtainment New Source Review(NANSR) Separator Venting Emissions Inventory 008 Separator Venting Facility AIRs ID: , �12�,,,,,,�� ,:,,,, :-9F3� „ „,...,: , _0081 �� j1,,,,,: County Plant Po�nt a Section 02-Eouioment Descriotion De4aiis Naiuoal;GasUent3pg.tn,lnska�e of gas pFpe3ine dowistttne . � �i �. :: ;,.'�. Detailed Emissions Unit Description: '" �� -� � � ` � ,„ Enc3osedf.ombusL""ors' "» .... • . ;, „ ,.� ,„;� . .. . ,... .. , . . . .... ; .-. . . Emission Control Device Description: Requested Oveall VOC&HAP Conirol Efficiency%: '�� S$'; �� LY.�,`%'/�///�m'��'�, Limited Process Parameter #�3#�r��as�bb��9�,„�y _i�_ . Gas meter Yas me�ei'75cuicei7Ylr�.a�5taif8�a#sd aRe��i[ii�! Section 03-Processine Rate Information for Emissions Estimates Primary Emissions-Separetor ActualThroughput= 6.J,�'�,MMscFperyear - RequestedPermitLimitThroughput= fi5.7.'.MMscfperyear RequestedMonthlyThroughput= 6 MMscfpermonth PotentialtoEmit(PTE)Throughput= 66MMsdperyear Process ConVol(Recycling) �I/Uy��.,. - Equipped with a VRU r.� y,� �,�,� Is VRU process equipment: � Secondary Emissions-Combustion Device(s)for Air Pollution Contro� Separator Gas Heating Value: 2i4Y!Btu/sd .Volume of waste gas emitted per BeL of liquidsthroughput: scf/bbl Section 04-Emissions Factors&Meihodolo¢ies � Description SiTe-5`pecifc sample Cak2n lfz7(207,7 at Vall Pad MW :622:766�:16/16-mol Displa<ementEquation Ex=Q*MW'Xx/C Weight% Helium �. fl.90C0'�. CO2 �: 3 476i1��. N2 ��. �7.7399��. meihane ��'�55.7�37'. ethane ��.'�.17.6843'�. � proPane ��.��.1?.852S��. isobutane 15`�Kl'�. n-hutane �� 4.�386 isopentane � 6.9506��. n-pentane 1.L5'6 cydopentane %� �J.7.�3`0: n-Hexane -i.__fl.3591'�. cyclohexane '.'. �7.�9Y4 Otherhexanes '� 0.514T� heptanes �: 9 3935�: methylcyclohexane C! 0.1642' 224-TMP �.�'. 0 OU6�: eenzene '� fl..^.418!. Toluene �� OS`^.fi-. Ethyl6enzene � 0 Obb�F- Xylenes �� O.C456� . C8+Heavies :�__i1.5gS6: Total �� 99 9092 VOC Wt% 2229 Emission Factors Separator Venting - Uncontrolled Controlled Pollutant (Ib/MMscf) . Qb/MMscf) Emissionfactor5ource (GasThroughput) (GasThroughput) VOC 12798.5530 639.9292 �� `'��k ��y%/3 t BenZene 24.0060 1.2003 ;� �; E��,r�`��s�atpsss Toluene 31.9314 159b6 K� „��i(Q�k�.g�8�S Ethylhenzene 3.6756 0,1838 �: �a+�.�,��J � . Xylene 26.i8S4 1.3094 ��"��g�� ; r�-Hexane 206.2333 10.3ll7 � � ?lqS�..-�'�, - 224TMP i5.8508 0.7925 �'�� ' ' �� ., _......a...::�... ..'. .r x "�:< Control Device Umm�trolied Uncontrolled � - Pollutant (Ib/MMBtu) Ib/MMscf EmissionFactar5ource (W as[e Heat Combusted} (GasThroughput) PM10 �.9475 8.509 $fi'' . �, �� PM2.5 O�:D075 8.509 F �/ �/,�T� �� C SOx D.0006 C.672 Zs�,� �� y�' . NOx ��a�:0686 77.656 � CO 0;310b 354A20 =�� ,.��.% ,,:,,,&�5 l��'� � 2 of 5 K:\PA\2018\18WEO111.CPl.xlsm Separator Venting Emissions inventory Section OS-Emissions tnventory � . Potential to Emit Ac[ual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Umm�trolled Controlled Uncontrolled Controlled Conirolled (tons/year) (mns/year) (tons/year) (tons/year) (tons/year) Qbs/month) PM10 0.28 0.00 0.00 0.28 0.28 47 PM2.5 0.28 0.00 0.00 0.28 0.28 47 SOx 0.02 0.00 0.00 0.�2 0.02 4 . NOx 2.55 �.00 �.D0 Z.55 2.55 433 VOC 420.43 �.G0 0.06 420.43 21.02 3571 � CO 11.63 0.00 0.00 11.63 11.63 1975 Potential to Emit Ac[ual Emissions Requested Permit Limits HazardousAirPollutants Uncontrolled Urtmntrolled Controlled Umm�trolled Controlled (16s/year) �Ihs/year� (Ibs/year) �I6s/year� (Ibs/year) BenZene 1577 � 0 1577 79 Toluerne 2098 � 0 2098 S0S Ethylbenrene 241 0 0 241 12 Xylene 1721 0 0 1721 86 n-Hexame 13550 0 0 13550 677 224 TMP 1a47 0 0 1041 52 Sec[ion06-Re ulato Summa Anal si Regulation 3,Parts A,B Source requires a permit ' Regulation 7,Sec[ion XVil.B,G 5ource is su6ject to Regulation 7,Section XVII.B.2,G Regulation 7,Section XVII.B.2.e The coniroi dev:re for this separetor is not su6jec[to Regulation 7,Section XVI1.8.2.e (See regulatory appli<ability worksheet for detailed analysis� Sec[ion 07-Initial and Periodic Samoline and Testine Reouirements Using Gas Throughpuito Monitor Compliance Does the mmpany use sRe specifc emission faRors based on a�as sample to estimate emissions? � '�� This sample should represent the gas outlet of the equipment covered underthis AIRs ID,and should have been collected within one year of the application received date.However,if the facility has not beer�modified(e.g.,no new wells brought on-line),then it may he appropriate to use an older site-speciFic sample. If no,the permit will mntain an'9nitial Tes[ing Requirement"to collect a site-specific�as sample from the equipment heing permitted and conduct an emission Factor analysis to danonstratethat the emission factors are lessihan or equal to the emissions factors esta6lished with this application. , Are facility-wide permi7Sed emissions oF VOC greaterihan or equal to 90 tons per year? -��'��'�.,;� If yes,ihe permit will cmtain: -An"Initial Testing RequiremenY'to collect a sitrspecifc gas sample from the equipment heing pzrmitted and conduct an emission factor analysis to demons[rate that the.. emission factors are lessthan or equal to the emissions factors established with this applicaiion. -A"PeriodicTesting RequiremenY'to collect a site-specific gas sample from the equipmeni 6eing permitted and conduct an emission fac[or analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application on an annual basis. Will the operator have a meter ins[alled and operational upon startup of this point? Yes If no,the pertnit will contain a condition ihat requires the operatorto calculate gasthroughput using the liquid throughput until the meter is ins[alled and operational(not to exceed 180 days).This condition will use the"bolume of was[e gas emitted per BBL of liquids throughput"(scf/bbl)value in sec[ion 03. Does the company reques[a control device e�ciency greaterthan 95%For a flare or com6ustion device? �d��'�� '��-�`��_'� If yes,the permit will mntain and initial mmpliance test condition to demonstrate the destruction effciency of the combustion device based � on inlet and outlet concentration sampling _ You have indicated a6ove that the monitored oro<ess paremeter is natural gas vented.7he folbwing questions do not require an answer. 3 of 5 K:\PA\2018\18WE0111.CPl.xlsm Separator Venting Emissions Inventory Section 08-Te<hmcal Analvsis Notes Sdr5pem€icgasanaly�isfromlf3l/2017.7hisEsaienostexa�lya4<arberer_'.hea�p3icai"oncv. s4,.mi«e�.S.uF,(ai�rnvifiis,as€aoniheiP�etnatamor�r�c_at.,amotewouldprovaemo�em?aningialdata`orenvirennenia��ane�i. '�. SUUrce has f�dic3ted thai a meber is al-ready on sise:�I wifl req�ire rr�e_enng n.tna,�.ermil'. Section 09-Inventory SCC Codin¢and Emissions Factors Uncontrolled Emissons AIRS Point k Process# SCC Code Pollutant FacEor Control% UnRs 008 0S 3-'10-001-SO Fiares PM30 3.51 0 IbjMM5CF PM2.5 5.51 0 Ib/MMSCF SOx 0.67 0 �b(MMSCF - NOx 77.v6 0 Ib(MMSCF VOC 12795.58 95 Ib/MMSCF CO 354.02 0 Ib/MMSCF Benzene 24.01 95 Ib/MMSCF Toluene 31.93 95 -Ib/MMSCF Ethylbenzene 3.68 95 Ib/MMSCF Xylene 26.i9 95 Ib/MMSCF n-Hexane 206.23 95 Ib/MMSLF 224 TMP 15.85 95 Ib/MMSCF - 4 of 5 K:\PA\2018\i8WE0111.CPl.xlsm Separatar Venting Regulatory Analysis wbrksheet ColoradoRe ulation3Par[sAandB-APENandPermltRe ulrements Source is inihe Yen-Attainment Area ATfAINMEM 1. Are unron[rolled actual emissians from any criteria pollu[ants(rom[his individual so�rce grea[er[han 2 TPY(Regulation 3,PartA,Sec[ion II.D1.a�7 l. Areto¢alfacilityurcontrolledVOCemissiansgr�terthan5TPV,NOxgreaterthanlOTPYorCOemissionsgreaterthanlOTPV�RegulaGon3,Part8,5ectionll.�.3)7 Not eoaugh Information NON ATfAINMENT 1. Are uncontrolled em ss ons from any cnte�a polWtants f�om th s nd v dual sourte g�eate�than�TPY�Regulat on 3,Part A,Sec9on II.�.1 a�7 Y45- �.5 <e Req 2. Are to[aI tac I ry unconirolled VOC em ss onsfrom the grealer than 2 TPY,NOx greater ihan 5 TPY orCO em ss ons greater than 10 TPV�Regulation 3,Part 8,5ection II.D.2)? Yes Sour<e Req Sourre requires a permit Coloada:Reeulation].Sec[ion%VII 1. Was Le well newlV�o�str�cted,hydraulically fractured,or recompleted an or aker Aug�st 1,2014? Y25 I: ,.,So�rce s si Source is sublett to fiegulation],Settion%VII.8.2,G Sec[im%VII.B.2—General Provisions far Air Pollution Control Equipment and Preven[ion of Emissions ' SecHan XVII.G-Emissions Conirol Alter�tive EmiszionsConiral(Ootionel5ectioM a. Is this separator controlled by a backwp ar alternate cambustion device Q.e.,nat the primary control device)that is not enclosed7 ..9 "The control The ontroi device iorihis separaCoris no[sublett to Reguletion],Section%Y11.8.2.e Sec['ion XV II.B.2.e—Altema[ive emissions cont�ol equipment . Disclaimer This document assists operators uvfh defermining applicability of certain requiremenfs of fhe Clean AirAct,ifs implementing regulations,and Air Quality Contro/Commission regulations.This document ls not a rule or regulation,and fhe arelysis it confains may nof appryto a pa�ficular sifuation based upon Ihe intlividual facts and circumstances.This documenf does not changa or substifufe ior any law, regulafion,or any otherlegalry binding requiremenf and is not legally enforceable.In the event oi any contiicf be(ween the language oi(his document and the language of fhe Gean Air Act„ifs implementing Iegula6ons,andAirQualityCon(rdCommissionregulations,thelanguageoithestaNteorregula6'onwillconfrol Theuseofnon-mandalorylanguagesuchas°recommentl,""may,"'should,"and'can,"is infended to descnbe APCD inlerpratalions antl recommenda(ions.Mantlalory te�minology such as'must"and"required"are inlended to descnbe controlling requirements underthe tenns of the Clean Air Act and Air Quality Conbol Commission regulations,buf this document does nof esfablish legally binding requirements in and oV itself. CDPHE Permit number: Date issued: Issued to: Construction Permit Air Pollution Control Division 18WE0111 Issuance: Cub Creek Energy, LLC 1 Facility Name: Vail Pad Plant AIRS ID: 9F1C Physical Location: SWNW quadrant of Section 12, Township 4N, Range 68W County: Weld General Description: Exploration Et Production Well Pad Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description VENT -1 008 Natural Gas Venting in instance of gas pipeline downtime Enclosed Combustors This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/ 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.) 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or AIRS ID: 123/9F1C Page 1 of 7 Health and Environment Air Pollution Control Division more; (iii) does no e of the estimated completion date. The Divisio n end ._,.f thee e. (Rey ion 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 PM10 PM2.5 NO. VOC CO VENT -1 008 --- --- 2.6 21 11.6 Point Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled VENT -1 008 Enclosed Combustors VOC & HAPs PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) AIRS ID: 123/9F1C Page 2 of 7 Health and Environment Air Pollution Control Division Process Limits Facility t Equipment ID -40At Point Process Parameter Annual Limit VENT -1 008 Gas Vented from Separator 66 MMSCF 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. 9. Upon installation of the flow meter, the owner or operator shall continuously monitor and record the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The owner or operator shall use monthly throughput records to demonstrate compliance with the process limits contained in this permit and to calculate emissions as described in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. 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) 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 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. 13. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the date of first production by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. OPERATING a MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to 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. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. AIRS ID: 123/9F1C Page 3 of 7 Periodic Testin' 16. This source is no rwise 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: Health and Environment Air Pollution Control Division 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. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet commenced on the source. The source shall not exceed the Federal program threshold until a permit is granted. (Regulation Number 3, Parts C and D). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all 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 AIRS ID: 123/9F1C Page 4 of 7 such final authori Requirements to, to f t tifx F Health and Environment Air Pollution Control Division thorizat to operate are located in the section this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to 'meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Cub Creek Energy, LLC AIRS ID: 123/9F1C Page 5of7 Notes to Permit Holder a 1) The permit holder is rtoeirae time =' is permit. An invoice for these fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) Health and Environment Air Pollution Control Division 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 Emission Rate (Ib/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 008 Benzene 71432 1577 Yes 79 n -Hexane 110543 13550 Yes 677 Toluene 108883 2098 Yes 105 Ethylbenzene 100414 241 No 12 Xylene 100414 1721 Yes 86 224 TMP 540841 1041 Yes 52 5) The emission levels contained in this permit are based on the following emission factors: Point 008: Pollutant Emission Factors Source Uncontrolled Controlled (lb/MMSCF) (Ib/MMSCF) Gas Vented from Separator Gas Vented from Separator NOx 0.068 0.068 AP -42 Chapter 13.5 Industrial Flares (NOx) VOC 12798.583 639.929 Extended gas analysis CO 0.31 0.31 AP -42 Chapter 13.5 Industrial Flares (CO) Benzene 24.006 1.2 Extended gas analysis n -Hexane 206.233 10.312 Extended gas analysis Toluene 31.931 1.597 Extended gas analysis Xylene 26.188 1.309 Extended gas analysis Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. AIRS ID: 123/9F1C Page 6 of 7 Health and Environment Air Pollution Control Division 6) In accordance with C fS. 25 1 11 1, ch Poltttanl,a mission ' tice (APEN) associated with this permit is valid f t of e m tdga was ry ed by the Division. A revised APEN shall be submit e no later Th i 3 ays be ore t e ive-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane PSD or NANSR Synthetic Minor Source of: VOC 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 XXXXXX AIRS ID: 123/9F1C Page 7 of 7 Natural Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and Application for Construction Permit Alt 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 L;'N 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 Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: AIRS ID Number: 123 /9F1C/ OCK [Leave blank unless APCD has already assigned a permit #' and AIRS ID] Company equipment Identification: VENT -1 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Section 1 - Administrative Information Company Name': Cub Creek Energy, LLC Site Name: Vail Pad Site Location: SWNW Sec. 12 T4N R68W Mailing Address: (Include Zip Code) 200 Plaza Drive, #100 Highlands Ranch, CO 80129 E -Mail Address: tracy.butzen@cub-creek.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Tracy Butzen Phone Number: 303-515-7050 1Please 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 address provided. Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 374398 Av COLORADO Permit Number: AIRS ID Number: 123 /9F1C/ / [Leave blank unless APCD has already assigned a permit Pt and AIRS ID] Section 2- Requested Action ✓❑ NEW permit OR newly -reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Please note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: (2) QTI Q5000 Enclosed Combustors Serial #'s Q5000 14-064 and Q5000 14-071 3 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: pipeline downtime Natural gas venting in instances of gas For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 05 / / 2017 / / O Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day Will this equipment be operated in any NAAQS nonattainment area Is this equipment located at a stationary source that is considered a Major Source of (HAP) Emissions days/week weeks/year 0 Yes ❑ No ❑ Yes lI No Form APCD-205 -Natural Gas Venting APEN - Rev 03/20))7 COLORADO Ay? th�r»un Kl Ilea, Etn,ranxt-.1 Permit Number: AIRS ID Number: 123 /9F1 C/ [Leave blank unless APCD has already assigned a permit ii and AIRS ID] Section 4 - Process Equipment Information O Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: ❑ Compressor Rod Packing Make: Model: ❑ Blowdown Events # of Events/year: ❑ Other Description: Serial #: Capacity: Gal/min # of Pistons: Leak Rate: Scf/hr/pist Volume per event: MMscf/event If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? (] Yes Natural Gas Venting Process Parameters4: Liquid Throughput Process Parameters4: ❑ No Maximum Vent Rate: 7 500 SCF/hr Vent Gas Heating Value: 1 ,142 BTU/SCF Requested: 65.70 MMSCF/year Actual: MMSCF/year -OR- Requested: Bbl/yr Actual: Bbl/yr 4 Requested values will become permit limitations. Requested limit(s) should consider future process growth Process Properties: Molecular Weight: VOC (mole %) 9.24% VOC (Weight %) 22.31% Benzene (mole %) 0.0116% Benzene (Weight %) 0.0417% Toluene (mole %) 0.0131% Toluene (Weight %) 0.0555% Ethylbenzene (mole %) 0.0013% Ethylbenzene (Weight %) 0.0063% Xylene (mole %) 0.0093% Xylene (Weight %) 0.0454% n -Hexane (mole %) 0.0907% n -Hexane (Weight %) 0.3594% 2,2,4-Trimethylpentane (mole %) 00053% . •(Weight 2,2,4-Trimethylpentane %) 0.0278% Additional Required Information: ❑� Attach a representative gas analysis (including BTEX Et n -Hexane, temperature, and pressure) Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and pressure) Aviv.. COLORADO Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 Permit Number: AIRS ID Number: 123 i 9F1 C / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.20923/-105.03403 Operator Stack ID No. Discharge Height Above Ground Level (Feet) Temp. r F) Flow Rate (ACFM) Velocity (ft/sec) Comb -1 &2 40 -1000 Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap 72 Section 6 - Control Device Information ❑✓ VRU: Pollutants Controlled: Size: Make/Model: Requested Control Efficiency VRU Downtime or Bypassed q ❑ Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: Type: Enclosed Combustor Make/Model: (2) QTI Enclosed Combustors Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency Minimum Temperature: MMBtu/hr 95 98 Waste Gas Heat Content Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested 0 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 AV COLORADO tiu%� b Er�.een-++rti Permit Number: AIRS ID Number: 123 i 9F1 Ci [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions?❑ Yes ❑ No If l de tribe the control e uipment AND state the overall control efficiency (% reduction): yes, p ease s Pollutant q Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO,, VOC Enclosed Combustor 95% CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? 2017 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions. Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM N/A N/A N/A N/A N/A SOX N/A N/A N/A N/A N/A NO), 0.068 lb/MMBtu AP 42 N/A 2.55 VOC 12800.09 Ib/MMscf Sample 420.48 21.02 CO 0.31 Ib/MMBtu AP 42 N/A 11.63 Benzene 23.91 Ib/MMscf Sample 0.79 0.04 Toluene 31.85 lb/MMscf Sample 1.05 0.05 Ethylbenzene 3.64 lb/MMscf Sample 0.12 0.01 Xylenes 26.05 Ib/MMscf Sample 0.86 0.04 n -Hexane 206.24 Ib/MMscf Sample 6.78 0.34 2,2,4-15.97 Trimethylpentane lb/MMscf Sample p 0.52 0.03 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 AVCOLORADO AIRS ID Number: 123 t 9F1 Ci Permit Number: [Leave blank unless APCD has already assigned a permit A 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. Signature of Legally Xuthoriz'ed Person (not a vendor or consultant) Tracy Butzen Landman Name (please print) Title 42 ,A7 r r Date Check the appropriate box to request a copy of the: Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) Send this form along with $152.90 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 Telephone: (303) 692-3150 Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https: //www.colorado.gov/cdphe/apcd ®vir COLORADO 6 G.Q.M., -, llrv'� b �'-+-_xenfsn Hello