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Home My WebLink About20183669 CDP E COLORADO CO 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 RECEIVED 1150 O St PO Box 758 Greeley, CO 80632 N0V 1 3 2010 November 5, 2018 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On November 8, 2018, the Air Pollution Control Division will begin a 30-day public notice period for Fifth Creek Energy Operating Company, LLC - Fox Creek 34-1 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 Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, / / Lam,, 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 "` a John W. Hickenlooper, Governor ' Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer Public, Rev;eu) cc PLCTP), Pwc eRICH/JAI/CK), F-Itr (ST) 2018-3669 I I / icl / 18" tI / 13 / Ig ,A CopHE Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: Fifth Creek Energy Operating Company, LLC - Fox Creek 34-1 Pad - Weld County Notice Period Begins: November 8, 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: Fox Creek 34-1 Pad Exploration Et Production Facility NENE of Section 34, T12N, R63W, Weld County Weld County The proposed project or activity is as follows: Crude Oil Tanks and associated activities 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 17WE0383 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 1Ili„� COLORADO Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details ......................__....... Review Engineer. Cfwis tagGl.enaeak-- Package#: 3,6S�6'�ig3 Received Date: .3/. `D 83 I RC :s ya₹ Review Start Date: 10 kl?:E IN Section 01-Facility Information Company Name: PlfthCreekEryeilie'Aper ttngicntnpany,LLC Quadrant Section Township Range County AIRS ID: plitti 'i - NENE` ! 34'i� !22N 63' • Plant AIRS ID: RF0S :-_- _ � Facility Name: Poctreek 64(1 Pad. _ - „-, _ - Physical Address/Location: NENE quadrant of Section 34,Township 12N,Range 63W County: Weld CountyL Type of Facility: E €RE_ `�i- What industry se mend C5 x �� i ,* " e, g !!,,,E# o nw in �� _ j a ._�:,3 is this facility located in a NAAQS non-attainment area? -r��L If yes,for what pollutant? O Carbon Monoxide(CO) fp Particulate Matter(PM) O Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Self Cert Engineering AIRS Point# Emissions Source Type Equipment Name Permit it Issuance# Action Control? Required? Remarks ,t _ Fermi i mill 003 C#ttc.e Ollattk TK-C1 J :Yes�".' :: 1?i;VEG3x3 ! 1 esr issu -� L - lit.II:4L I lidin! I Section 03-Description of Project C-ude ai!tanks. - - _ Section 04-Public Comment Requirements Is Public Comment Required? t Yes "If yes,why? ,€ ' l`�„ac ,J'Perini₹,- �r h' .,,,, , , , cif s,.-: _.__,_. Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? ig ,viri� If yes,for what pollutants? 33= 3 s i 3! 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? ,TL. - , If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) `[...j '—"" CI ❑� Non-Attainment New Source Review(NANSR) Is this stationary source a major source? A: If yes,explain what programs and which pollutants hen SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) .._ e-- Title V Operating Permits(OP) Non-Attainment New Source Review(NANSR) , • • Crude Oil Storage Tank(s)Emissions Inventory 012 Crude Oil Tank 123 9,05 012 Facility AIRs ID: County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit 93 ,.�' six eorl sma;ge Tanksjjl Description: _ „�aJ,��'�.�'pt'�`�.�4F. Emission Control Device Enclosed Combustor Description: Requested Overall VOC&HAP Control Efficiency%: '�.45.......,...,; Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= .277,4001 Barrels(bbl)per year Actual Crude Oil Throughput While Emissions Controls Operating= )j^237;403- Requested Permit limit Throughput= 277,400 Barrels(bbl)per year Requested Monthly Throughput= - 23560 Barrels(bbl)per month Potential to Emit(PTE)Throughput= X332 88)x!Barrels(bbl)per year Secondary Emissions-Combustion Device(s) , Heat content of waste gas- 3;3835-Btu/scf 3 Volume of waste gas emitted per BBL of liquids 3 i��)fl3': produced= ............::--_.2scf/bbl Actual heat content of waste gas routed to combustion device= 26,084 MMBTU per year Requested heat content of waste gas routed to combustion device= 26,084 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 31,301 MMBTU per year Componen LHV(Btu/sc mole% HHV(Btu/:lb/hr Water 0 0 0 0 Section 04-Emissions Factors&Methodologies CO2 0 3.82037 0 0.011627 N2 0 1.67245 0 0.00323994 Will this storage tank emit flash emissions? ��',' methane 909.4 29.084 1010 0.0322658 ethane 1613.7 21.5356 17697 0.044781 1=3=11111ECCIEMEMINI propane 2314.9 26.7505 2516.2. 0.0815725 Uncontrolled Controlled isobutene 3000.4 2.5239 3252 0.0101445 Pollutant (lb/bbl) (lb/bbl) Emission Factor Source n-butane 3010.8 9.29544 3262.4 0.0373618 (Crude Oil (Crude Oil Throughput) Throughput) isopentane 3699 1,52073 4000.9'. 0.0075875 3,20".-:.,:".' F n-pentane 3706.9 1.82478 4008.7 0.00910452 MIIIIMEMIE 0.0460 0.00230 tE Cyclopen r 3512 0.205046 3763.6 0.0009944661 0.00000 4- Cyclone 4179.7 0 4481.6 MEICIZEMEM 0.0000009,51,:deieeK' Hexanes!: 4403.8 1.258 4756 0.00477336 0.00000 heptanes 5100 0.212492 5502.5 0.001472431 0"2450: iirraMM ' i 'v,aihY!cYc!, 4363.7 0.074362 5215.9 0.000504914 IMIMEESIOEIIIIIMI 0.00000 -.- r: ....,a` Octanes, 5796 0.062592 6248.9 0.0004944321 Control Device Nonanes 6493.2 0.013009 6996.4 0.000115384 Uncontrolled Uncontrolled Uecanes+ 7189.5 0.015659 7743 0.000166642 Pollutant (Ib/MMBtu) -(lb/bbl) Emission Factor Source - Benzene ; 3590.9 0.069805 3741.9 0.000377081 (waste heat (Crude Oil \ combusted) Throughput) Toluene 4273.7 0.040148 4474.9 0.000255811 IMMIZII 0.0070 0.0007 Ettiylbenza 4970.4 0.00416 5222 3.05403E-05 IMMZETE 07 0.05 011007 6 - XVenes rA 4957.1 0.01172 5208.7 8.60462E-05 0.1380_ 0.0130 - n-Haxane 4403.8 4756 0.00272352 MMSIIIIIIMEEMIll 0.0259 c a:.�' 224 TMP i 5778.8 0.005163 6231.6 4.08246E-05 92S 586.8 0 637.'1 i Section 05-Emissions Inventory 99.99993 Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits - VOC 0.157806271 Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) VOC . 532.6 443.8 22.2 443.8 22.2 3770 PM10 0.1 0.1 0.1 0.1 0.1 17 PM2.5 0.1 0.1 0.1 0,1 0.1 17 NOx 2.2 1.8 1.8 1.8 1.80 306 CO 4.3 3.6 3.6 3.6 3.59 610 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) pbs/year) (lbs/year) (Ibs/year) (lbs/year) Benzene 15312 12760 638 12760 638 Toluene 0 0 0 0 ' 0 Ethylbenzene 0 0 0 0 0 Xylene 0 0 0 0 0 n-Hexane 81556 67963 3398 67963 3398 224TMP 0 _ 0 0 0 0 Section 06,-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Section((MB,Cl," C.3 Storage tank is subject to Regulation 7,Section XVII,B,Cl" &C.3 Regulation 7,Section)0/II.C.2 Storage tank Is subject to Regulation 7,Section XVII.C.2 Regulation 6,Part A,NIPS Subpart Kb Storage Tank Is not subject to N5PS Kb Regulation 6,Part A,NIPS Subpart 0000 Storage Tank is not subject to NOW 0000 Regulation 8,Part E,MACT Subpart HH Storage Tank is not subject to MACE HI-I (See regulatory applicability worksheet for detailed analysis) 2 of 4 K:\PA\2017\17WE0383.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? L, If yes,are the uncontrolled-actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year? - Yea 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 atthe facility being permitted? 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 efficiency of the combustion device based on inlet and outlet concentration sampling Section 08-Technical Analysis Notes. tit Operatgr has sedan assumed heatloading of 4022.06 MMBtu/yrfor waste gas.I have adjusted the assumed gas to oil"ratio t6 agree wrth this r `� 1fi 13 js311 v • dog,vu 3 3�l iii .4 3 Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled Emissions AIRS Point R Process R SCC Code _ Pollutant Factor Control% Units 012 01 _ � ('yG4 ,. 7 v-" p8 s.a,,,„..,,:,`_ PM10 0.02 0 lb/1,000 gallons ccude oil throughput PM2.5 0.02 0 lb/1,000 gallons crude oil throughput NOx 0.31. 0 lb/1,000 gallons crude oil throughput VOC 76.2 95 lb/1,000 gallons made oil throughput CO 0.62 0 lb/1,000 gallons crude oil throughput Benzene 1.10 95 lb/1,000 gallons crude oil throughput Toluene 0.00 95 lb/1,000 gallons crude oil throughput Ethylbenzene 0.00 95 lb/1,000gallons crude oil throughput Xylene 0.00 95 lb/1,000 gallons crude oil throughput n-Hexane 5.83 95 lb/1,000 gallons crude oil throughput 224 TMP 0.00 95 lb/1,000 gallons crude oil throughput • 3 of 4 K:\PA\2017\17WE0383.CP1.xlsm Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Pa res A and B-APEN and Permit Requirements rwurce is in the Attainment Area - ATTAINMENT 1. Are uncontrolled actual emissions from any criteria polluonO from this indlwdual source greater than 2 TPY(Regulation 3,Part A,Section II.D:1.a)? S"ES 7.Source Req 2. Is the construction date prior M4/14/2914 and not modified after 4/14/14(See PS Memo 14-03 for additional guidance on grandfather applicability)? tt `,[(SP Go to subq, 2a.If answer to#2 Is yes,is the crude oil throughput less than 40,000 gallons per year? wow"Go to next, 3. Are total facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than 10 TPY or CO emissions greater than 10TPY(Regulation 3,Part 0,Section 11.03)? '>y"f(C%(f!`il(Source Req Source requires permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section 11.0.1.5)? (/ 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)? - nJ 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 greater than 2 TPY,hill greater than 5TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)? y/"." 'You have indicated that source is in the Attainment Area Colorado Regulation 7,Section XVII 1. Is this tank located at a transmission/storage facility? - No Continue-' 2. Is this crude oil storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor stations or natural gas processing plant? Yes Continue-' 3. Is this wde.oil storage tank a fixed roof storage tank? 'Hs -'=Go to then 4. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? Y .'f.iSource is sr 'Storage tank's subject to Regulation 7,Section XVII,s,C.1&C.3 - Section XVII.B-General Provisions for Alr Pollution Control Equipment and Prevention of Emissions Section)(VILLA-Emissions Control and Monitoring Provisions Section XVII.C3-Recordkeeping Requirements 5. Does the crude oil storage tank contain only"stabilized"liquids?If no,the following additional provisions apply. IWSKAISource is sr 'storage tank Is subject to Regulation 7,Section XVII.C.2 Section XVII.C2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR.Part 60,Subpart Its,Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(ms)(-472001.I? - l Go to then 3. Does the storage vessel meet the following exemption In 60.111b(d)(4)? kiW1.1 Storage Tar 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 storage tank constructed,reconstructed,or modified(see definitions 40 CFR,60.2)afterJuly 23,19847 4. Does the tank meet the definition of"storage vessel"'in 60.11167 5. Does the storage vessel More a"volatile organic liquid(VOL)'as defined in 60.1116? 6. Does the storage vessel meet any one of the following additional exemptions: NO= 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 ms(-950 BBL]and stares a liquid with a maximum true vapor pressurea less than 3.5 kPa(60.110b(b))?;or c.The design capacity Is greater than or equal to 75 Mr[-'472 BBL]but less than 151 m'[^950 BBL]and stares a liquid with a maximum true vapor pressure less than 15.0 kPa(60.11ob(b))? Storage Tank Is not subject to NSPS 1@ Subpart A,General Provisions §Be.112b-Emissions Control Standards for VOC §60.113b-Testing and Procedures §60.115b-Reporting and Recordkeeping Requirements §60.116b-Monitoring of Operations 40 CFR,Part 60.Subpart 0000.Standards of Performance for Crude Oil and Natural Gas Production,Transm boron and Distribution 1. Is this crude ail storage vessel located at a facility in the onshore ail and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-' 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? Yea "?Go to then 3. Are potential VOC emissions'from the individual storage vewei greater than or equal to 6 tons per year? WSW 4. Does this crude oil storagevessel meet the definition of"storage vessel"'per 60.5430? €,/ '°'L, 'Storage Tank is not subject to NSPS 0000 Subpart A,General Provisions per§60.5425 Table 3 §60.5395-Emissions Control Standards for VOC §60.5413-Testing and Procedures§60.5395(g)-Notification,Reporting and Recordkeeping Requirements §60.5416(c)-Cover and Closed Vent System Monitoring Requirements §60.5417-Control Device Monitoring Requirements [Note:If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination data,n should remain subject to NSPS 0000 per 605365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR,Pert 63,Subpart MACT HH,Oil and Gas Production Facilities 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: Yes Continue-' a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760(5)(2));OR b.A facility that processes,upgrades or stores natural gas prior to the point at which natural gas enters the ratural gas transmission and storage source category or is delivered to a final end users(63.760(a)(3))? 1. Is the tank located at afacigty that is majors for HAPs? t ;N Storage Tar 3. Does the tank meet the deinitlon of'storage vessel""In 63.761? Itac' 4. Does the tank meet the deinition of"storage vessel with the potential for flash emissions'per 63.761? N 7 @ 5. Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 00007 .„, 'Storage Tank isnot subject to MACE HH Subpart A,General provisions per§63.764(a)Table 2 §63.766-Emissions Control Standards 463.773-Monilndng 063.774-Recordkeeping §63.775-Reporting RACE Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area.lithe tank meets both criteria,then review RACE requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Qualify Contrcd Commission regulations.This document is not a rule oreegu/ation,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 Ovally 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 APCQ interpretations and recommendations.Mandatory terminology such as must"and'required"are intended to describe controlling requirements under the terms of fhe Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself Y AT\ EtCDPHE Construction Permit Air Pollution Control Division Permit number: , 17WE0383 Issuance: I Date issued: Fifth Creek Energy Operating Company, Issued to: LLC Facility Name: Fox Creek 34-1 Pad Plant AIRS ID: 9F05 Physical Location: NENE quadrant of Section 34, Township 12N, Range 63W County: Weld General Description: Exploration Et Production Well Pad Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID TK-01 003 Six (6) 400 bbl crude oil stoarge Tanks Enclosed Combustor This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, t y 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.) AIRS ID: 123/9F05 Page 1 of 8 olora, Depa, e � f b Health and Environment Air Pollution Control Division 3. This permit shall ;xpir f the o ff; er ope ato ,of the s ,"`` ce for which this permit was issued: (i) doe '- .341rnet ceo, . uctf , ificat , r operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Equipment Point Emission Type ID PM10 PM2.5 NOX VOC CO TK-01 003 --- --- --- 22.2 3.6 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Delete this paragraph if you have removed the monthly emissions limits from the permit. 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.) AIRS ID: 123/9F05 Page 2 of 8 olora Depa_ erg f b Health and Environment Air Pollution Control Division Facilit ' ' Equipment• Sg Pollutants ., Ccofice ID Controlled TK-01 003 Enclosed Combustor 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.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID TK-01 003 Oil Throughput 277400 BBL 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: AIRS ID: 12319F05 Page 3 of 8 „ olora,,. Depa et f b Health and Environment Air Pollution Control Division • All combustion devi s i ;-tall-d orr- r af4-r May 1 014, must be equipped with an opergn&, uto , i n ig w �n of th 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. OPERATING Et MAINTENANCE REQUIREMENTS 14. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEM 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 complete site specific sampling including a compositional analysis of the pre-flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing shall be in accordance with the guidance contained in PS Memo 05- 01. Results of testing shall be used to determine site-specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site-specific sampling and analysis shall be submitted to the Division as part of the self-certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 16. 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 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. AIRS ID: 12319F05 Page 4 of 8 olora - . Depane" s f b Health and Environment Air Pollution Control Division s , P ADDITIONAL RE UIREMENTS . r 18. A revised Air P Emiftibb time@(AID that be frte . (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 (NO,) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50%or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. AIRS ID: 12319F05 Page 5 of 8 Air PollutionHealth Controland DivisionEnvironment 21. This permit is is$'; ed i � relnc' upo the accracy an. ompleteness of information supplied by thez �or,opeja i „` ned giappa 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. gy; . Christian Lesniak Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to Fifth Creek Energy Operating Company, LLC AIRS ID: 12319F05 Page 6 of 8 olorarr Depa; e, f y b Health and Environment Air Pollution Control Division Notes to Permit Holder it the tme" f 's p mit suaace: 1) The permit holder is-c fired �ay = or t t actssing` m#a for this 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.) 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. Uncontrolled Emission Are the Controlled AIRS Rate emissions Emission Rate Point Pollutant CAS # (lb/yr) reportable? (lb/yr) Benzene 71432 12760 Yes 638 003 n-Hexane 110543 67963 Yes 3398 5) The emission levels contained in this permit are based on the following emission factors: Point 003: Emission Factors Uncontrolled Controlled Pollutant (Ib/BBL) (Ib/BBL) Source Oil Throughput Oil Throughput VOC 3.2 0.16 Crude Oil State E.F. (includes flash) CO 0.276 0.276 TNRCC Flare Emissions Guidance (CO) Benzene 0.046 0.002 Crude Oil State E.F. (includes flash) n-Hexane 0.245 0.012 Crude Oil State E.F. (includes flash) 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 AIRS ID: 123/9F05 Page 7 of 8 R ,olora "` Depa e f z b"y Health and Environment Air Pollution Control Division " r €,. 1 rc3 by the Division. A reyjsed fEN�ha E be $ bm ed S1 later t n 30 days before the five- year term expires efer~o te st re._ " nual f voice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, n-Hexane, Total HAPs 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, Appendix A - Appendix I Appendixes 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: 123/9F05 Page 8 of 8 AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit—Crude Oil Storage Tank(s)' Permit Number: I7WEj3g3 [Leave blank unless APCD has already assigned a permit#&AIRS ID] Emission Source AIRS ID: /Z3 / 9,rO3 / 603 Facility Equipment ID: TK-01 [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 01 —Administrative Information Section 02—Requested Action(Check applicable request boxes) Company Name: Fifth Creek Energy Operating Company LLC NAICS,or 211111 ® Request for NEW INDIVIDUAL permit SIC Code: ❑ Request for coverage under GENERAL PERMIT GP08 Source Name: Fox Creek 34-1 Pad ❑ Request MODIFICATION to existing INDIVIDUAL permit(check boxes below) Source Location: NENE Section 34,T12N,R63W County: Weld ❑ Change process or equipment ❑ Change company name Elevation: 5,350 Feet ❑ Change permit limit ❑ Transfer of ownership ❑ Other Mailing Address: 5251 DTC Parkway,Suite 420 ZIP Code: 80111 ❑ APEN Submittal for Permit Exempt/Grandfathered source Greenwood Village,CO ❑ APEN Submittal for update only(Please note blank APEN's will not he accepted) Person To Contact: Kent Gilbert Phone Number: (303)478-8393 Addl.Info. E-mail Address: KGilbert@fifthcreekenergy.com Fax Number: &Notes: Section 03—General Information For existing sources,operation began on: / / For new or reconstructed sources,the projected startup date is: 01 / 23 / 2017 This Storage Tank is Exploration&Production Midstream or Downstream hours/ days/ weeks/ E&P( )Site Located at: ® ❑ Normal Fl f S Oi day 7 week 52 year Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes ® No Are Flash Emissions anticipated at these tanks ® Yes ❑ No ► Are you requesting>6 ton/yr VOC emissions,or are uncontrolled actual emissions>6 ton/yr? ® Yes ❑ No ► Are these crude oil tanks subject to Colorado Oil and Gas Conservation Commission(COGCC)805 series rules?If so,submit Form APCD-105. ❑ Yes ® No General description of equipment purpose: Crude Oil Storage Tanks Section 04—Storage Tank(s) Information Crude Oil Requested Permit Limit: 277,400 bbl/year Colorado Department of Public Health and Environment Air Pollution Control Division(APCD)This notice is valid for five throughput: Actual: bbl/year Actual While Controls Operational: bbl/year (5)years. Submit a revised APEN prior to expiration of five-year Average API Gravity of Sales Oil: degrees RVP of Sales Oil term,or when a significant change is made(increase production,new Tank Design: Fixed Roof: ® Internal Floating Roof: ❑ External Floating Roof: ❑ equipment,change in fuel type,etc). Mail this form along with a check for$152.90 per APEN for non- Storage #of Liquid Manifold Total Volume of Installation Date of most recent E&P,midstream and downstream sources or$152.90 for up to Date Of First Production Tank Storage Vessels in Storage Tank storage vessel in storage tank five(5)APENs for E&P sources and$250 for each general permit ID Storage Tank (Month/Year) g (bbl) (Month/Year) registration to: TK-01 6 2400 01/15/2017 01/23/2017 Colorado Department of Public Health& vironment APCD-SS-BI ' fyr 4300 Cherry Creek Drive South 1Pp ('`F: Denver,CO 80246-1530 a ''��/1. Wells Serviced by this Storage Tank or Tank Battery(E&P Sites Only) For guidance on how to complete this P f`oFrit:, Air Pollution Control Division: �n7, t"'303 692-3150 API Number Name of Well Newly Reported Well (, `'(' ) 05-123-42580 Fox Creek 223-342211 ® Small Business Assistance Program(SBAP): (303)692-3148 or (303)692-3175 ® 05-123-42583 Fox Creek 501-340311 APEN forms:http://www.colorado.gov/cdphe/oilgasAPENS ❑ Application status: http://www.colorado.gov/cdphe/permitstatus El FORM APCD-210 Page 1 of 2 Fox Creek 34-I CrudeTankAPEN 20170424 361500 - - - - - - - - AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit—Crude Oil Storage Tank(s)' Permit Number: Emission Source AIRS ID: /7,,,3/ 9cO3/ Section 05—Stack Information(For Midstream sites only) Section 06—Stack(Source,if no combustion) Location(Datum&either Lat/Long,or UTM) Operator Stack Base Stuck Discharge PHorizontal Datum UTM UTM Casting or UTM Northing or Method of Collection for Stack Elevation Height Above Temp. Flow Rate Velocity Moisture Ground Level (°P) (ACFM) (NAD27,NAD83. Zone Longitude Latitude Location Data(e.g.map, ID No. (feet) (11/sec) (�°) WGS84) (12 or 13) (meters ers or degrees) (meters or degrees) GPS.Googlc[arth) I M'GS84 40.97228 -104.41258 COGCC Direction of stack outlet(check one): El Vertical ❑ Vertical with obstructing raincap O Horizontal O Down 0 Other(Describe); Exhaust Opening Shape&Size(check one): © Circular:Inner Diameter(inches)= 48 ❑ Other:Length(inches)= Width(inches)= Section 07—Control Device Information ❑ Vapor Recovery Unit(VRU)used for control or the Storage Tank(s) ® Combustion Device used for control(tithe Storage Tank(s) Rating: MMBIu/hr Size: Make/Model: Type: Cimarron Make/Model 48" I1VECD(2 units) Requested VOC&I!AP Control Efficiency: 'U VOC& MAP Control Efficiency: Requested: 95 '%, Manufacturer Guaranteed: 98 04 Annual time that VRU is bypassed(emissions vented): "/„ Minimum temp.to achieve requested control: °F Waste gas heat content: Diu/scf ❑ Closed loop system used for control of the storage tank(s) Constant pilot light? ® Yes ❑ No Pilot burner rating: MMt3tu/hr Description: ❑ Describe Any Other: Section 08—Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 150 psig Please describe the separation process between the well and the storage tanks: The well flows to a horizontal separator,the oil is separated out and sent to the oil storage tanks. Section 09—Emissions Inventory Information & Emission Control Information O Emission Factor Documentation attached Data year for actual calendar yr.emissions below&throughput in Sec.(14(e.g.20117): I Pollutant Emission Factor Actual Calendar Year Emission'- Requested Permitted Emissions Emission Factor Uncontrolled Basis, Units Uncontrolled(Tons/Year) Controlled(Tons/Year) Uncontrolled(Tons/Year) Controlled(Tons/Year) Data Source NOx 0.138 lb/MMBtu 1.8(1 "ICE() VOC 3.20 Ib/bbl 443.8 22.2 CDPHE CO 0.2755 I b/M M 13 t u 3.59 TCEQ Benzene 11.046 I'gbh I 6.38 0.32 CDPHE Toluene Ethylbenzene Xylenes n-I lexane 0.245 lb/bbl 33.99 1.70 CDPHE 2,2.4-Trimethy(pentane Please use the APCD Non-Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Section 10—Ap plicant 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 covcra a under general pf rmit C (Ili,1 yr bier certify that this source is and will be operated in full compliance with each condition of general permit Gr08. L-- '_/ J (14/24/2017 Kent Gilbert Vice President-Operation Sign tune of Person Legally Authorized to Supply Data Date Name of Legally Authorized Person('lease print) • Title You may he charged an additional APEN fee iCAPEN is tilled out incorrectly or missing information and requires re-submittal. Annual emissions lees will be based on actual emissions reported here. Additional O Attach a pressurized pre-(lush crude oil extended liquids analysis.RVP&API analysis of the post-flash oil Information O Attach E&P Tanks input&emission estimate documentation(or equivalent simulation report/test results) Check box to request copy admit permit prior to issuance. Required: O Attach EPA TANKS emission analysis if emission estimates do not contain workuig/brcathtog losses _® Check box to request copy or droll permit prior to public notice. FORM APCD-210 Page 2 of 2 Fox Creek 34-I CrudeTankAPEN 20170424 Hello