HomeMy WebLinkAbout20182869.tiffCOLORADO
Department of Public
Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
August 28, 2018
Dear Sir or Madam:
RECEIVED
SEP 0 4 2018
WELD COUNTY
COMMISSIONERS
On August 30, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for
Highpoint Operating Corporation — Anschutz Equus Farms 4-62-33 NWNW. 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 & Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
PLACIICC PLCIVIM/TP), HLC3-r)
�t�ia��s pwC£.R(CH(3M /C1C)Oct
2018-2869
CDPHE
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Highpoint Operating Corporation — Anschutz Equus Farms 4-62-33 NWNW — Weld County
Notice Period Begins: August 30, 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: Highpoint Operating Corporation
Facility: Anschutz Equus Farms 4-62-33 NWNW
oil and gas well production facility
NWNW, Section 33, T4N, R62W
Weld County
The proposed project or activity is as follows: applicant proposes a oil and gas well production facility
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 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 18WE0437 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:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
RADO
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Heath b Environment
CONSTRUCTION PERMIT
18WE0437 Issuance: 1
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
HighPoint Operating Corporation
Anschutz Equus Farms 4-62-33 NWNW
123 9D8D
NWNW, Section 33, T4N, R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment ID
AIRS
Point
Equipment Description
Emissions Control
Description
OTK101-115
009
Fifteen 400 barrel condensate storage 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, 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 more; (iii) does not complete
constriction 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.)
COLORADO
Air Pollution Control Division
Page 1 of 7
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:
Equipment ID
AIRS
Point
Tons per Year
Emission
e
Type
PM2.5
NO,
VOC
OTK101-115
009
--
3.6
33.8
13.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month total
is calculated based on the previous twelve months' data. The permit holder shall calculate actual
emissions each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
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.)
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
OTK101-115
009
Enclosed combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
OTK101-115
009
Condensate
2,663,478 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
COLORADO
Air Pollution Control Division
Page 2 of 7
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. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
11. This source is subject to Regulation Number 7, Section XII. The operator shall comply with all
applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control requirements
for condensate storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Section XII.C.) (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 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.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING & MAINTENANCE REQUIREMENTS
15. 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.)
COLORADO
Air Pollution Control Division
Page 3 of 7
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
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.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five (5)
tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) 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.
COLORADO
Air Pollution Control Division
Page 4 of 7
Details for obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction, installation
and operation of the source, in accordance with this information and with representations made by
the owner or operator or owner or operator's agents. It is valid only for the equipment and
operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge
to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such
occurrence, this permit shall be deemed denied 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:
Kirk Bear
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
HighPoint Operating Corporation
COLORADO
Air Pollution Control Division
Page 5 of 7
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation
Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based
on the consumption rates requested in the permit application. These limits may be revised upon
request of the owner or operator providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and
complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to the
Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
009
Benzene
71432
1891
95
Toluene
108883
1252
63
Xylenes
1330207
400
20
n -Hexane
110543
14116
706
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission
Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
Source
NOx
0.0680 lb/MMBtu
CDPHE
CO
0.31001.b/MMBtu
CDPHE
VOC
0.5100 lb/bbl
operator
71432
Benzene
0.0007 lb/bbl
operator
108883
Toluene
0.00051b/bbl
operator
1330207
Xylene
0.0002 lb/bbl
operator
110543
n -Hexane
0.0053 lb/bbl
operator
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
COLORADO
Air Pollution Control Division
Page 6 of 7
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
NANSR
Synthetic Minor Source of: VOC, HAP
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found
at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
COLORADO
Air Pollution Control Division
Page 7 of 7
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Kirk Bear
Package #: 378539
Received Date: 4/24/2418
Review Start Date:. 8/13/2013
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? = Yes
If yes, for what pollutant? ❑ carbon Monoxide (CO) Particulate Matter (PM)
H igh poirt,Operating Corporation
§q8D
Anschi
Equus Farms
NWNW quadrant of Section 33, Township 4N, Range 62WW
Weld County
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
62W
NWNW
Ozone (NOx & VCC)
4N
AIRS Point #
Emissions Source Type
-Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
009
Condensate Tank
OTK101-115
Yes .
18WE0437
1
Yes
Permit Initial
Issuance
010
Produced Water Tank
WiK1D1-WTK103
Yes
18WE0438
1
:'Yes
Permit Initial
Issuance
011
<.-Lie aid Loading
11001
-- -Yes
18WE0439
1
-Yes:
Permit Initial,
issuance
013
separzting
FLARE001
Yes
18W60441
1
YeS, -
Permit initial
issuance
Section 03 - Description of Project
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here SO2 NOx
Prevention of Significant Deterioration (PSD)
No
Yes
502 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑d
CO VOC PM2.5 PM10 TSP HAPs
DDIEIDEI ❑
Colorado Air Permitting Project
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
❑_❑H❑ODD
Condensate Storage Tank(s) Emissions Inventory
009 Condensate Tank
Facility AIRS ID:EMNIMi
_ M. --
Plant
Point
Section 02- Equipment Description Details
Detailed Emissions Unit `fftee[1300 barrel condensate tanks
Description:
Emission Control Device enc)oeed coe*unL
Description: 3r ,
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput =
Potential to Emit (PTE) Condensate
Throughput=
2';663,4781; Barrels (bbl) per year
2,663,478 Barrels (bbl) per year Requested Monthly Throughput=
Actual Condensate Throughput While Emissions Controls Operating =
226213 Barrels (bhl) per month
2663,4,7* Barrels (bbl) per year
(
663 479' Barrels (bbl) per year
a3k fit:
Secondary Emissions - Combustion Device(s)
3f3�73
Heat content of waste gas = r'��3.33331311111i33� .� Btu/scf
Volume of waste gas emitted per BBL of liquid
cf/bbl
produced=.=s
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
Emission Factors
Condensate Tank
Pollutant
VOC
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
0.5100:_
0.0007
0.0005
(Condensate
Throughput)
0.0255
0.0000
0.0000
0.0000
0.0000
0.0003
0.0000
Control Device
Benzene
Toluene
Ethylbenzene
Xylene
0.0002
0.0053
n -Hexane
224 IMP
Pollutant
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted(
(Condensate
Throughput)
Emission Factor Source
PM10
PM2.5
NOx
CO
9.0680-::.- -....
0.310Q:
Section 05 - Emissions Inventory
0.0000
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Omits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx
CO
679.2
679.2
34.0
679.2
34.0
5768
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
ribs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
ribs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1891
1891
95
1891
95
1252
1252
63
' 1252
63
0
0
0
0
0
400
400
20
400
20
14116
14116
706
14116
706
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section 011.0, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, N5PS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart OOO0
Storage Tank is not subject to NSPS OOOO
Regulation 8, Part E, MACT Subpart OH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
0.9455
0.6259
0.0000
0.1998
7.0582
0.0000
0.0473
0.0313
0.0000
0.0100
0.3529
0.0000
3 of 16
I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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 drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it maybe appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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 OS - Technical Analysis Notes
Section 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point N Process It SCC Code
009
01#
t.
Uncontrolled
Pollutant Emissions Control % Units
Factor
PM10 0.00 0 lb/1,000 gallons condensate throu
PM2.5 0.00 0 lb/1,000 gallons condensate throw
NOx 0.00 0 lb/1,000 gallons condensate throu
VOC 12.1 95 lb/1,000 gallons condensate throw
CO 0.00 0 lb/1,000 gallons condensate throu
Benzene 0.02 95 lb/1,000 gallons condensate throw
Toluene 0.01 95 lb/1,000 gallons condensate throe
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throw
Xylene 0.00 95 lb/1,000 gallons condensate throe
n -Hexane 0.13 95 lb/1,000 gallons condensate throe
224 TMP 0.00 95 lb/1,000 gallons condensate throe
4 of 16 I:\Oil & Gas Public Notice \18W E0437\18W E0437.PAxlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B -APEN and Permit Requlrements
'Source Is in the Nan -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from the individual source greater than 2TPY(Regulation 3, Part A, Section II.O.1.a)7
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo GS -01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total (edify uncontrolled VOC emissions g≤eater than 5 TPY, NOxgreater than lO TPY or CO emissions greater than to IP/ (Regulation 3, Part B, Section 11.03)1
'Not enough information
NON -ATTAINMENT
1. Are uncontrolled emisiors from any creda pollutants from the Indhdual source greater than l TPY (Regulation 3, Part A, Section ll.O.l.a)?
2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Oefingions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emeslom greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 30 TPY (Regulation 3, Part B, Section 11.02)?
'Source requires a pemdt
Colorado Regulation 7. Section XII.CS
1. Is the storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is the storage tank located at an oil and gas aploation and production operations, natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
'Storage tank Is subject to Regulation 1, Section OII.n-F
Section PII.C3 —General Requirements for Air Palkrtlon Control Equipment —Prevention of Leakage
Section Al. —Emission Estlnsation Procedures
Section AID —Emissions Control Requirements
Section ml.E—Monitoring
Section AI -F— Recordkeeping and Reporting
Colorado Regulation?, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does the storage tank exhibit 'Flash" (e.& storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC7
'Storage Tank Is not subject[, Regulation?, Section X11.0
Section AlG2-Emlsslons Control Requirements
Section AI21 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section MI.C.2—Emission Estimation Procedures
Colorado Regulation?, Section MI
1. Is this tank located at a transmission/storage facility?
2. Is the condensate storage tanks located at an oil and gas aploatlon and production operation , well production facility', natural gas compressor stations or natural gas processing plant?
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions' of this forage tank equal to or teeter than 6 tons per year VOC?
'Storage tank Is subject to Regulation?, Section In In, B, C3 a C.3
Section XNI.0—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
5ectlon XNI.C3 - Recordkeeping Requirements
Does the condensate storage tank contain only "stabilized" liquids?
'Storage tank is subject to Regulation?, Section XVII.C.0
Section oolI.C2 -Capture and Monitoring for Storage Tanks feted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. a the individual storage vessel capacity greater than or equal to 75 cubic meters (m) (`472 BBlsj?
2. Does the storage vessel meet the following exemption in 6o.121b(d)(4)?
a. Doe the vessel has a deign capacity less than or equal to 1,589.874 m' l^10,000 BBL) used for petroleum" or condensate sttred,processed, orirated prior to custody transfer' as defined in 60.11lb?
3. Was the condensate storage tankconrtruttd, remnrtro¢ed, or modified (see definitions 40 CFR, 60.2) afterluly 23, 1984?
4. Does the tank meet the definition of'rtoragev0ser' In 60.111b?
5. Does the storage vessel store a"volatile organic liquid (VOL)"' as defined In 60.1116?
6. Does 'beverage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in arm of 204.9 kPa (-29.7 pail and without emissions to the atmosphere (60.110b(d)(2)(?; o
b. The design capacity's greater than or equal to 151 m' ('950 BBL] and stores a liquid with a maximum true vapor pressure' less than 35 kPa (6o110b(b))7; or
c The design capacity' greater than or equal to 75 M' ("472 Will but less than 151 m' 1"950'BBLI and store a liquid with a maximum true vapor pressure' less than 15.0 kpa(6o.110b(b))?
'Storage Tank Is not subject to NSPS lob
Subpart A, General Provisions -
§60112b- Emissions Control Standards for VOC
4601136 -Tasting and Procedures
4601156 -Reporting and Recoiokeeping Requirements
4601166- Monitoring of Operations
4o CFR. Part 60, Subpart 0000, standards of Performance for Crude On and Natural Gas Production. Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and na0al gas production segment, natural gas processing segment or natural gas transmission and storagesegment of the industry?
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year?
4. Doe this condensate storage vessel meet the definition of "storage vesser" per 60.5430?
5. Is the rtoage vessel subject to and controlled in accordance with requirements for store a vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH?
'Storage Tank is not subject to NSPS 0000
SubpartGeneral Provisions per §605425 Table 3
460.5395- Emissions Control Standards for VOC
4605413 - Testing and Procedures
460.5395(8)- Notification, Reporting and Recordkeeping Requirements
460S416(c)- Cover and Closed Vent System Monitoring Requirements
460.5417- Control Device Monitoring Requirements
(Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tom per year VOC on the applicability detemdnamon date, It should remain subject to NSPS 0000 per 6o5365(e)(2) even
If potential VOC emissions drop below 6 tom per year]
40 CFR, Part 63. Subpart MAR HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that mats either of the following criteria:
a. A facility that processes, upgrade or stores hydrocarbon liquids' (63260(a)(2)); OR
b. A facility that processes, upgrades orstor0 natural gas prior to the point at which natural gas enters the natural gastransmnsian and storage source category or is delivered to a final end user' (63.760(a)(3)I?
2. Is the tank located at a facility that's major for HAPs?
3. Does the tankmeet the definition of "storage vessel."' In 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761?
5. Is the tank subject[, control requremenis under. CFR Part 60, Subpart Kb or Subpart 0000?
'Storage Tank Is not sublt4:t to MALT NH
Subpart A, General provisions per§63.764 (a) Table 2
463.766 - Emissions Control Standards
463.773 - Monitoring
463.774- Recordkeeping
463.775 -Reporting
RACT Review
RACT review is required If Regulation 7 does not apply AND lithe tank is In the nomattainment area. If the tank meets both cdteda, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implemenh'ng regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not charge or substitute for any law.
regulation, or any other legally biding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Conhol Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may,"should,' and 'can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and 'required are intended to describe controlling requirements under the tens of the Clean Air Act
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of 000/f
Yes
yes
Yes -
no
Yes:."'
No
yes
Source Req
Go to nod
Source Req
Continue-'
Continue-'
Source a st
Continue-'
Storage Tar
Source [so.
Continue-'
Go to then
Go to then
Source est
Storage Tar
Yes
Continue-'
Storage Tar
Go to the n
Go to then
'Yes 'Continue -'
Storage Tar
Produced Water Storage Tank(s) Emissions Inventory
010 Produced Water Tank
Facility AIRS ID:
tt-C.'!fr3ity
9080
Plant
D
Poin
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
ree;400 barrel produced
enclosed -:combustor
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
'Requested Permit Limit Throughput =
Potential to Emit (PTE) Produced Water
Throughput = 1500 000 Barrels (bbl) per year
;.500101 Barrels (bbl) per year
t;504;ciao Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas= IId 37 ;� j' Btu/scf
Volume of waste gas emitted per BBL of liqui
produced= „ y�ifr, scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Actual Produced Water Throughput While Emissions Controls Operating =
Requested Monthly Throughput = 127397 Barrels (bbl) per month I
0 MMBTU per year
0 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Pollutant
Pollutant
Produced Water Tank
Uncontrolled
Controlled
(lb/bbl)
(Ib/bbl)
(Produced Water
Throughput)
0;0520..=
0.0009'. S.'.
0:0002
,..0:.0007.
(Produced
Water
Throughput)
0.0026
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Control Device'
Uncontrolled Uncontrolled
(Ib/MMBtu)
(lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
0.0000
0.0000
0.0000
0.0000
Emission Factor Source
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits -
Controlled
(lbs/month)
VOC
PM10
PM2.5 -
NOx
CO
39.0
39.0
2.0
39.0
2.0
331
0.0
0.0
0.0
0,0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
1335
1335
67
1335
67
360
360
18
360
18
0
0
0
0
0
0
0
0
0
0
1035
1035
52
1035
52
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
0.6675
0.1800
0.0000
0.0000
0.5175
0.0000
0.0334
0-0090
0.0000
0.0000
0.0259
0.0000
6 of 16
I:\Oil & Gas Public Notice\18WE0437\18WE0437.PA.xlsm
Produced Water Storage Tank(s) Emissions Inventory
Section 07- Initial and Periodic Sampling and Testing Requirements
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 water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to
use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point N Process if SCC Code
010 01 404-00315 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons liquid throughput
PM2.5 0.00 0 lb/1,000 gallons liquid throughput
NOx 0.00 0 lb/1,000 gallons liquid throughput
VOC 1.2 95 lb/1,000 gallons liquid throughput
CO 0.00 0 lb/1,000 gallons liquid throughput
Benzene 0.02 95 lb/1,000 gallons liquid throughput
Toluene 0.01 95 lb/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.02 95 lb/1,000 gallons liquid throughput
224 TMP 0.00 95 lb/1,000 gallons liquid throughput
7 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.
Colorado Regulation 3 Parts A and B - APES and Permit Requirement
'Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from anycritena pollutants from this individual source greater than 2 TPY(Regulation 3, Pert h, Section ll.D.1.a)?
2. Is the operator claiming less than 1% crude oil and Is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part 5, Section II.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 1111.3g
'You have indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 1.0.1.0)?
2. Is the operator claiming less than 1% crude oil and'i0 the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D-1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOz greater than 5 TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section 11.11.2)?
f,Es',.11bj�v�
'Source requires a permit
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 fans per year VOC?
No
yes
'storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Section XVII.B— General Provisions for Air Pollution Can trol Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVIl.C.3 - Recordkeeping Requirements
5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
'Storage tank is subject to Regulation 7, Section XVII-C.2
Section XVII.C.2 - Capture and Monitoring far Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Dlstdbutlon
1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the Industry?
2. Was this produced water storage vessel constructed,reconstructed, or modifled(see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430?
'Storage Tank is not subject to NSps 0000
Subpart A, General Provisions per §60.5425 Table 3
§60.5395- Emissions Control Standards for VOC
§60.5413 -Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(c): Cover and Closed Vent System Monitoring Requirements
§60.5417 -Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
RACT Review
RACE review is required if Regulation 7 does not apply AND tithe tank Is In the non -attainment area. R the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, ifs implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis if contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," 'may,'
-should," and 'can,"is intended to describe APCD interpretations -and recommendation. Mandatory terminology such as 'must" and 'required" are Intended to describe controlling requirements under -
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Yes
Source Req
Go to next
Source Reg
Continue -'
Continue -
-
Go to the n
Source is st
Source is st
Continue-'
Storage Tar
Storage Tar
Go to then
Hydrocarbon Loadout Emissions Inventory
011 Liquid Loading
'Facility AIRs ID:
Pia
Section 02 -Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Effiden y:
Control Efficiency:
95.00
Requested Overall VOC& HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded = C:
'Requested Permit Um it Throughput =
Potential to Emit (PTE) Volume Loaded =
)BAP Barrels (bbl) per year
565: Barrels (bbl) per year
65,% Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating =
Requested Monthly Throughput = 188511 Barrels (bbl) per month
2,2f9 5 WW,. Barrels (hbl) per year
Secondary Emissions - Combustion Devlce(s)
Heat content of waste gas=
Volume of waste gas emitted per year=
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Btu/scf
3054258 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
UI
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Volume Loaded)
(Volume
Loaded)
0.0118
0.0000
0.0000
0.0000
0.0000
0.0002
0.0000
VOC
0.2360::
0.000E
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
0.0036
Pollutant
Control Device
Uncontrolled Uncontrolled
__ (Ib/MMBtu) (lb/bbl)
(Volume
(waste heat combusted) Loaded)
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
Emission Factors
Hydrocarbon loadout
Emission Factor Source
he state default emissions factors may be used to estimate emissions.
Emission Factor Source
PM10
PM2.5
SOx
NOx
CO
Section 05 - Emissions Inventory
0:3100..::.
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tom/year)
- Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tans/yeari
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
sox
NOx
VOC
CO
0.60
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
-- 261.91
261.91
13.10
261.91
13.10
2224
0.00
0.00
0.00
0.00
0.00
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
ilbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/yeari (Ibs/yeari
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
xylene
n -Hexane
224 TMP
910
910
46
910
46
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7990
7990
400
7990
400
0
0
0
0
0
90116
I:\Oil & Gas Public Notice\ 18WE0437\18WE0437.PAxlsm
Hydrocarbon Loadout Emissions Inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
RACT- Regulation 3, Part B, Section IIL0.2.a
(See regulatory applicebitiity worksheet for detailed analysis)
Source requires APEN, Is permR exempt
RACT does not apply
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device? /1
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 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point it
011
Process if
01
5CC Code
4-06-00132 Crude Oil: Submerged Loading Normal Service (5=0.0)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 b/1,000 gallons transferred
PM2.5 0.00 0 b/1,000 gallons transferred
500 0.00 0 13/1,000 gallons transferred
NOx 0.00 0 b/1,000 gallons transferred
VOC 5.6 95 b/1,000 gallons transferred
CO 0.00 0 b/1,000 gallons transferred
Benzene 0.01 95 b/1,000 gallons transferred
Toluene 0.00 95 6/1,000 gallons transferred
Ethylbenzene 0.00 95 6/1,000 gallons transferred
Xylene 0.00 95 6/1,000 gallons transferred
n -Hexane 0.09 95 b/1,000 gallons transferred
224 TMP 0.00 95 6/1,000 gallons transferred
10 of 16 I:\Oil & Gas Public Notice \18W E0437\18W E0437.PA.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
'Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissionsfrom anycriteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1,1)7
3. Is the loadout operation loading less than 10,000 gallons (238 OBEs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
S. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
'You have Indicated that source Is in the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 3.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBts) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbis per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbis per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B,Section 3.0.2)?
(Source requires APEN, is permit exempt
Ndj;".;s;? 2 NI
7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy(Regulation 3, Part B, Section lll.u.2.a)?
'RAC? does not apply
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation WI! control. The use of non -mandatory language such as 'recommend, —may/ "should,"and 'can," is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as `must" and 'required' are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
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The loadou
The loadou
Separator Venting Emissions Inventory
013 Separator Venting
Facility AIRS ID:
County
'„,gf&kailingididggnandalliral
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
emergency$
Emission Control Device Description:
Requested Overall VOC & HAP Contra
Limited Process Parameter
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Separator
Actual Throughput =
20,0 MMscf per year
Requested Permit Limit Throughput = .20,Oi MMscf per year Requested Monthly Throughput= 2 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
20 MMscf per year
iO
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04- Emissions Factors & Methodologies
Description
MW
Weight
Helium
CO2
N2
methane
ethane
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
Total
VOC Wt
0.00
0.00
to/scf
scf/bbl
Ib/Ib-mol
Displacement Equation
Ex=4*MW*Xx/C
12 of 16 I:\Oil & Gas Public Notice \18W E0437\18W E0437.PA.xlsm
Separator Venting Emissions Inventory
EEDETE
Pollutant
Pollutant
Section 05- Emissions Inventory
Separator Venting
Uncontrolled
(Ib/MMscf)
Controlled
(lb/MMscf)
35420.0000
isor0000
68.0000
0.0000
18.4000
660.0000
0.0000
1771.0000
7.5000
3.4000
0.0000
0.9200
33.0000
0.0000
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
Ib/MMscf
0.0075_,_
0.0006 : ::.....
0.0680i'..
(Gas Throughput)
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
0.12
0.12
0.12
0.12
0.12
PM2.5
0.00
0.00
0.00
0.00
0.00
SOx
0.01
0.01
0.01
0.01
0.01
NOx
1.07
1.07
1.07
1.07
1.07
VOC
354.20
354.20
17.71
354.20
17.71
CO
4.88 '
4.88
4.88
4.88
4.88
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(lbs/year) (lbs/year)
(lbs/year) (lbs/year)
Benzene
3000
3000
150
3000
150
Toluene
1360
1360
68
1360
68
Ethylbenzene
0
0
0
0
0
Xylene
368
368 -
18
368
18
n -Hexane
13200
13200
660
13200
660
224 TMP
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.8.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07- Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Source requires a permit
Source is subject to Regulation 7, Section XVII.B.2, G
The control device for this separator is subject to Regulation 7, Section XVII.B.2.e
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRS ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -speck as sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor 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 installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 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
13 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Separator Venting Emissions Inventory
You have indicated above that the monitored process parameter is natural gas vented. The Following que
14 of 16 I:\Oil & Gas Public Notice \18W E0437\18WE0437.PA.xlsm
Separator Venting Emissions Inventory
Section 08 - Technical Analysis Notes
AIRS Point #
Section 09 - Inventory 5CC Coding and Emissions Factors
Process # 5CC Code
013 01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 11.74 0 lb/MMSCF
PM2.5 11.74 0 lb/MMSCF
SOx 0.93 0 lb/MMSCF
NOx 107.10 0 lb/MMSCF
VOC 35420.00 95 lb/MMSCF
CO 488.25 0 Ib/MMSCF
Benzene 150.00 95 lb/MMSCF
Toluene 68.00 95 Ib/MMSCF
Ethylbenzene 0.00 95 Ib/MMSCF
Xylene 18.40 95 Ib/MMSCF
n -Hexane 660.00 95 Ib/MMSCF
224 TMP 0.00 95 Ib/MMSCF
15 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B- APEN and Permit Rquiremems
[Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
'Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 11.0.1 a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than STPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)?
'Source requires a permit
Colorado Regulation 7, Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014?
[source Is subjectto Regulation 7, Section XVII.B.2, G
Section XVII.B.2—Genera] Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional Section)
a. Is this separator controlled bya back-up or alternate combustion device (I.e., not the primary control device) that Is not enclosed?
[The control device for this separator Is subject to Regulation 7, Section XVII.B.2.e
Section.XVII.B.2e — Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situah'on based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,""may,""should,"and "can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must' and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Yes '41Source ce Req
Yes:.... Source Req
YThe control
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
CONSTRUCTION PERMIT
18W E0439
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
HighPoint Operating Corporation
Anschutz Equus Farms 4-62-33
123 9D8D
NWNW, Section 33, T4N, R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TL001
011
Truck loadout of condensate
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, 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.qov/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.qov/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 more; (iii) does not complete
COLORADO
Air Pollution Control Division
Page 1 of 7
construction within a reasonable time of the estimated completion date. The Division may grant
extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. The operator shall retain the permit final authorization letter issued by the Division, after completion
of self -certification, with the most current construction permit. This construction permit alone does
not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations. (Reference: Regulation
Number 3, Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
TL001
011
--
0.4
13.1
1.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits for criteria pollutants OR for both criteria and hazardous air
pollutants shall be determined on a rolling twelve (12) month total. By the end of each month a new
twelve month total is calculated based on the previous twelve months' data. The permit holder shall
calculate actual emissions each month and keep a compliance record on site or at a local field
office with site responsibility for Division review.
6. The emission points in the table below shall be operated and maintained with the emissions control
equipment as listed in order to reduce emissions to less than or equal to the limits established in
this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment ID
AIRS
Point
Control Device
Pollutants Controlled
TL001
011
Enclosed Combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B,
II.A.4)
Process/Consumption Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
TL001
011
Condensate
2,219,565 barrels
The owner or operator shall calculate monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month
total. By the end of each month a new twelve-month total is calculated based on the previous
COLORADO
Air Pollution Control Division
Page 2 of 7
twelve months' data. The permit holder shall calculate throughput each month and keep a
compliance record on site or at a local field office with site responsibility, for Division review.
8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation
Number 3, Part B, III.E)
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
11. This source is located in an ozone non -attainment or attainment -maintenance area and is subject
to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3,
Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and
emissions shall be controlled by a flare. (Reference: Regulation 3, Part B, III.D.2)
12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and
maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the
maximum extent practicable.
13. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the
atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2):
a. The owner or operator shall inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor
loss during loading and unloading. The inspections shall occur at least monthly. Each
inspection shall be documented in a log available to the Division on request.
b. All compartment hatches at the facility (including thief hatches) shall be closed and latched
at all times when loading operations are not active, except for periods of maintenance,
gauging, or safety of personnel and equipment.
c. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers
shall be weighted and properly seated.
d. Inspect pressure relief devices (PRD) annually for proper operation and replace as
necessary. PRDs shall be set to release at a pressure that will ensure flashing, working
and breathing losses are not vented through the PRD under normal operating conditions.
e. Document annual inspections of thief hatch seals and PRD with an indication of status, a
description of any problems found, and their resolution.
14. For this controlled loading operation, the owner or operator shall follow loading procedures that
minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference:
Regulation 3, Part B, III.D.2):
a. Install and operate the vapor collection and return equipment to collect vapors during
loading of tank compartments of outbound transport trucks.
b. Include devices to prevent the release of vapor from vapor recovery hoses not in use.
c. Use operating procedures to ensure that hydrocarbon squid cannot be transferred unless
the vapor collection equipment is in use.
d. Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
OPERATING & MAINTENANCE REQUIREMENTS
COLORADO
11. Air Pollution Control Division
Page 3 of 7
15. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division or
other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or
other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a
change in annual actual emissions of one (1) ton per year or more or five percent,
whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of
five percent or 50 tons per year or more, whichever is less, above the level reported
on the last APEN submitted.
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity; or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
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
COLORADO
Air Pollution Control Division
Page 4 of 7
the operation or activity commences and has been verified by the APCD as conforming in all
respects with the conditions of the permit. Once self -certification of all points has been reviewed
and approved by the Division, it will provide written documentation of such final authorization.
Details for obtaining final authorization to operate are located in the Requirements to Self -
Certify for Final Authorization section of this permit.
21. This permit is issued in reliance upon the accuracy and completeness of information supplied by
the owner or operator and is conditioned upon conduct of the activity, or construction, installation
and operation of the source, in accordance with this information and with representations made by
the owner or operator or owner or operator's agents. It is valid only for the equipment and
operations or activity specifically identified on the permit.
22. Unless specifically stated otherwise, the general and specific conditions contained in this permit
have been determined by the APCD to be necessary to assure compliance with the provisions of
Section 25-7-114.5(7)(a), C.R.S.
23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge
to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such
occurrence, this permit shall be deemed denied 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:
Kirk Bear
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to HighPoint Operating Corporation
COLORADO
Air Pollution Control Division
Page 5 of 7
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation
Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based
on the consumption rates requested in the permit application. These limits may be revised upon
request of the owner or operator providing there is no exceedance of any specific emission control
regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and
complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to the
Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(Ib/yr)
011
Benzene
71432
910
46
n -Hexane
110543
7990
400
Note: All non -criteria reportable pollutants in the table above w.th uncontrolled emission rates above 250 pounds per
year (Ib/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission
Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Pollutant
CAS #
Uncontrolled
Emission Factors
lb/bbl
Source
NOx
0.0680
AP -42
CO
0.3100
AP -42
VOC
0.2360
Operator
Benzene
71432
0.00041
CDPHE
n -Hexane
110543
0.00360
CDPHE
Note: Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
COLORADO
Air Pollution Control Division
Page 6 of 7
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
NANSR
Synthetic Minor Source of: VOC, HAP
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
COLORADO
Air Pollution Control Division
Page 7 of 7
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Kirk Bear'
Package if: 378539
Received Date: 4/24/2018
Review Start Date: 8/13/2018"
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? ❑ Carbon Monoxide (CO)
HighpointOperating Corporation
123
9080
Anschutz Equus Farms
NW NW quadrant of Section 33, Township 4N, Range 62W W
Weld County
Section 02 - Emissions Units In Permit Application
El
Particulate Matter (PM)
Quadrant
Section
Township
Range
62W
WNW
33l
4N
Ozone (NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit It
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
009
Condensate Tank ` "
OTK101-115
Yes
18WE0437
1
Yes
Permit €nitial
Issuance
010
Produced Water Tank" `-
WTK101-WTK103
Yes
18WE0438
1
Yes
Permit Initial
Issuance
011
LJquid Loading
11001
Yes
18W50439
1
Yes
Permit Init€a€
Issuance
013
5eparatorVenting
FLARE001
Yes
18WE0441
1
Yep':
Permit €nitial
Issuance
Section 03 - Description of Project
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 -Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? iNo
If yes, for what pollutants?
............
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
NO
Yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
J
-1
El
Is this stationary source a major source? No
If yes, explain what programs and which pollutants her( SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD)
❑ DODD ❑ _ _
Colorado Air Permitting Project
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
❑_❑g ❑ ❑❑❑
Condensate Storage Tank(s) Emissions Inventory
009 Condensate Tank
'Facility AIRs ID:
County
Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Actual Condensate Throughput =
(Requested Permit Limit Throughput =
Potential to Emit (PIE) Condensate
Throughput =
Actual Condensate Throughput While Emissions Controls Operating =
;563,47$' Barrels (bbl) per year Requested Monthly Throughput =
226213 Barrels (bbl) per month
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquid cf fibl
produced=s /
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Barrels (bbl) per year
u/scf
0 MMBTU per year
0 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Pollutant
VOC
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
0.0255
0.0000
0.0000
0.0000
0.0000
0.0003
0.0000
Control Device
Benzene
Toluene
Ethylbenzene
Xylene
�313�lllll -..
n -Hexane
224 IMP
-Pollutant
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/bbl)
(waste heat
combusted)
(Condensate
Throughput)
Emission Factor Source
PM10
PM2.5
NOx
CO
0.0000
0.0000
0.0000
0.0000
:...0,0680 z. v
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
VOC
PM10
PM2.5
NOx
CO
679.2
679.2
34.0
679.2
34.0
5768
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
Toluene
Ethylbemene
Xylene
n -Hexane
224TMP
1891
1891
95
1891
95
1252
1252
63
1252
63
0
0
0
0
0
400
400
20
400
20
14116
14116
706
14116
706
0
0
0
0
0
Section 86 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank Is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MAC' Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
0.9455
0.6259
0.0000
0.1998
7.0582
0.0000
0.0473
0.0313
0.0000
0.0100
0.3529
0.0000
(
3 of 16
I:\Oil & Gas Public Notice \38W E0437\18W E0437.PAxlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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 drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it maybe appropriate to use an older site -specific sample.
lino, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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 09 - Inventory 5CC Coding and Emissions Factors
AIRS Point # Process # 5CC Code
009 01
Uncontrolled
Pollutant Emissions Control % Units
Factor
PM10 0.00 0 lb/1,000 gallons condensate throw
PM2.5 0.00 0 lb/1,000 gallons condensate throu
NOx 0.00 0 lb/1,000 gallons condensate throw
VOC 12.1 95 lb/1,000 gallons condensate throu
CO 0.00 0 lb/1,000 gallons condensate throe
Benzene 0.02 95 lb/1,000 gallons condensate throu
Toluene 0.01 95 lb/1,000 gallons condensate throe
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throu
Xylene 0.00 95 lb/1,000 gallons condensate throe
n -Hexane 0.13 95 lb/1,000 gallons condensate throu
224 TMP 0.00 95 lb/1,000 gallons condensate throw
4 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Paris A and 8 - ADEN and Permit Requirements
'Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants fromthe Individual source greater than 2 TP1 (Regulation 3, Part A, 5ectionll.D.1.a)?
2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than lO TPY or CO emissions greater than 10.TPY (Regulation 3, Part 8, Section 11.0.3)?
'Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from the indvidual same greater than 1 TPY (Regulation 3, Part A, Section 11.0.1.x)7
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TP1, NOx greater than 5 TPY or CO emissions greater than 10 TP1 (Regulation 3, Part B, Section 10.D.2)7
'Source requires a pemtln
Colorado Regulation 7. Secion1RI.C-F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attain Them/maintenance area?
2. Is thfsstoage tank located at an oil and gas exploration and production operations, natural gas ampressorstatlon or natural gas drip station?
3. is this storage tank located upstream of a natural gas processing plant?
'Storage rank Is sublet[to Regulation 7, Section OII.C-F
Section 101.01 -General Requirements for Or Pollution Control Equipment -Prevention of Leakage
Section X11.02 -Emission Estimation Procedures -
Section 151.n -Emissions Control Requirement
Section XII.E-Monitoring
Sedan 1SSP-Recordkeeping and Reporting
Colorado Regulation 7. Section 011.0
1. Is this storage tank located In the 3 -hr ozone control area or any ozone non -attainment area or attainment/maintenance areal
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit"Flash" (e.g storing non -stabilised liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tom per year VOC?
'Storage Tank is not sublet, to Regulation 7, Section XII.G
Section AI.02 - Emissions Control Requirements
Section XII.C.1 -General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section XII.C2—Emission Estimation Procedures
Colorado Regulation 7. Section XVII
1. Is this tank located ate transmission/storage facility?
2. Is this condensate storageta nit` located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' or natural gas processing plant?
3. Is this condensate starageta nk a fired roof storage tank?
4. Are uncontrolled actual emissions' of this storage tank equal to cur greater than 6 tons per year VOC?
'Storage tank Is sublet[ to Regulation 7, Section Mil, 8, 0.1 N C3
Section XVILB —General Provisions for Air Pollution Control Equipment and Prevention of Emisslons
Section IMI.C3 - Emissions Control and Monitoring Provisions
Section Xi/IBC-3 - Recordkeeping Requirements
5. Does the condensatestorage tank contain only"stabilized"liquids?
'Storage tank is subject to Regulation 7, Section gVu.C.2
section XVII.C2 - Capture and Monitoring for Storage Te nits fitted with Air Pollution Control Equipment
4o CFR. Part 60. Subpart Kb. Standards of Performance for Volatile Organic Douid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 abk meters (m5) I-472 RBIs)?
2. Dom the storage vessel meet the following exemption In 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589374 m5(-10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined in 00.1110?
3. Was the condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Dom the tank meet the definition of"storage vmsera in 60.1110?
5. Dom the storage vessel store a"volatile organic liquid (VOL)"sas defined in 60.1110?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate In exams of 204.9 kPa (`29.7 psi] and without emissions to the atmosphere (60.110b(d)(2)1?; or
b. The design capacity a greater than or equal to 151 ms ('950 BBL] and stores a liquid with a maximum true vapor pressures less than 35 kPa (6o.110b(b))7; or
c The design capacity is greater than or equal to 75 M' (`472 BBL] but less than 151 m' (^950 BBL] and stores a Squid with a maximum tae vapor pressure° less than 15.0 kpa(60.110blb))?
'Storage Tank Is not subject to NSPS Kb
Subpart& General Provisions
§601120- Emissions Control Standards for VOC
§6o.113b -Testing and Procedures
960115b- Reporting and Recordkeeping Requirements
§60.1160- Monitoring of Operations
40 CFR, Part 60, Subpart0000. Standards of Performance for Crude Oil end Natural Gas Production, Transmission and Distribution
1. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was the condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 602) between August 23, 2011 and September 1g, 2015?
3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tans per year?
4. Does this condensate storage vessel meet the definition of"storage vessers per 605430?
5. Is the stoage vessel subject to and controlled in accordance with requirements forOoage vessels in 40 CFR Part 605ubpza Kb or 40 CFR Part 63 Subpart RH?
'Stores, Tank Is not subject to NSPS 0000
Subpart & General Provisions per §605425 Table 3
060.5395- Emissions Control Standards for VOC
§605413 -Testing and Procedures
44053551g) - Notification, Reporting and Recordkeeping Requirements
4005416(c) - Cover and Closed Vent System Monitoring Requirements
§605417 - Control Device Monitoring Requirements
(Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tans per year VOC on the applicability determination date, ft should remain subject to NSPS 0000 per 6o.536S(e)(2) even
If potential VOC emissions drop below 6 tons per year]
40 CFR. Part 63, Subpart MAR HH. Oil and Gas Production Facilities
1. Is the storage tank located at an oil and nasal gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or storm hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that processes, upgrades ornores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category ore delivered toe final end user' (63,760(a)(3))7
2. Is the tank bated at a facility that's major for HAPs?
3. Ooes the tank meet the definition of "storage vmser° in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential forflash emiions' per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
'Storage Tank Is nor sublect to MAR HH
SubpartA, General provisions per 563.764(a) Tablet
§63.766 - Emissions Control Standards
§63.773 -Monitoring
§63.774- Recordkeeping
§63.775 -Reporting
RACT Review
RACT review is required If Regulation 7 does not apply AND lithe tank Is In the non-atalnment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining epplicabdity of certain requirements of the Clean Air Act, its implementing regulations, and A7 Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual /ads and circumstances. This document does not change or substitute for any law,
regulation, or any other legally bindrg requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Alr Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The 1150 of non -mandatory language such as 'recommend°"may,"'should.' and 'can,"is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and 'required are intended to describe controlling requirements under the leans of the Clean Air Act
and Air Quality Control Commission regulations. but this document does not establish legally bindng requirements in and of itself
Yes
yes
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Yes
no
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No
yes
Source Req
Go to next.
Source Req
Continue-'
Continue-'
Source is st
Continue-'
Storage Tar
Source is ft
Continue-'
Go to then
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Souce is u
itteKi -'source asst
Storage Tar
Yes
vA
�We11R{s
gmign
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Storage Tar
Go to then
Go to then
Storage Tar
Produced Water Storage Tank(s) Emissions Inventory
010 Produced Water Tank
Facility AIRs ID:
County
Plant
Point
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
Requested Permit Limit Throughput = MR,M60000) ,₹.r$0 '000'' Barrels (bbl) per year
000} Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating =
Requested Monthly Throughput = 127397 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced= 'im_ ,, Iscf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Barrels (bbl) per year
Btu/scf
0 MMBTU per year
0 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Produced Water Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Produced Water
Throughput)
(Produced
Water
Throughput)
VOC
Benzene
Toluene
0.0520
0.0000
SO
0.0026
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
Control Device
Ethylbenzene
Xylene
n -Hexane
224 TMP
0.00070.
Emission Factor Source
Emission Factor Source
Pollutant
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
PM10
PM2.5
0.0000
0.0000
0.0000
0.0000
NOx
CO
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
VOC
PM10
PM2.5
NOx
CO
39.0
39.0
2.0
39.0
2.0
331
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1335
1335
67
1335
67
360
360
18
360
18
0
0
. 0
0
0
0
0
0
0
0
1035
1035
52
1035
52
0
0
0
0
0
Section 06- Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, Cl & C3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C2
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
0.6675
0.1800
0.0000
0.0000
0.5175
0.0000
0.0334
0.0090
0.0000
0.0000
0.0259
0.0000
l00
6 of 16
I:\Oil & Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Produced Water Storage Tank(s) Emissions Inventory
Section 07- Initial and Periodic Sampling and Testing Requirements
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 water sample drawn
at the facility being permitted and analyzed using flash liberation analysis?This sample should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to
use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point S
010
Process It SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons liquid throughput
PM2.5 0.00 0- lb/1,000 gallons liquid throughput
NOx 0.00 0 lb/1,000 gallons liquid throughput
VOC 1.2 95 lb/1,000 gallons liquid throughput
CO 0,00 0 lb/1,000 gallons liquid throughput
Benzene 0.02 95 lb/1,000 gallons liquid throughput
Toluene 0.01 95 1b/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.02 95 lb/1,000 gallons liquid throughput
224 TMP 0.00 95 lb/1,000 gallons liquid throughput
7 of 16
Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might he might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSP5 Kb.
Colorado Regulation 3 Parts A and B -APEN and Permit Requirements
Source is In the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteda pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.0.1.M)
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 B, Section 11.0.3)?
You have Indicated that source is in the Non -Attainment Area
NON -ATTAINMENT
1. Am uncontrolled emissions from any criteria pollutants from this individual source greater than STPY (Regulation3, Part A, Section lI.D.1.a)?
2. Istbe operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)?
(Source requires a permit
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor stations or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions' of this storage tank equal to or greater than B tans per year VOC?
'Storage tank is subject to Regulation ?, Section XVII, B, C.1 & C.3
Section XVII.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1-Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply.
'Storage tank is subject to Regulation ?, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this produced water storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? -
4. Does this produced water storage vessel meet the definition of"storage vessel"' per 60.5430?
'Storage Tank is net subject ta 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- Central Device Monitoring Requirements
[Note: Ca storage vessel Is previously determined to be subject to NSPS 0OOO due to emissions above 6 tons per year VOC on the applicbility determination date, it should remain subject to NSPS 0OOO per 60.5365(e)(2)
even if potential VOC emissions drop below 6 tons per year]
RACT Review
RACT review is required 0 Regulation 7 does not apply AND if the tank is in the non-attalnment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend," 'may,"
"should," and 'can,'is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required" are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Ye WA
No
yes
Yes
Source Req
Go to nests
Source Req
Continue-'
Continue-'
Go to the n
Source is st
Continue -'
Storage Tar
Storage Tar
Ge to the n
Hydrocarbon Loadout Emissions Inventory
011 Liquid loading
(Facility AIRS ID:
3
County
0
Plan
Oll ?;?A
Point
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
is this loadout controlled?
Collection Efficiency:
Control Efficiency:
condensate tank truck loadout
enc ed;combostop-
Requested Overall VOC & HAP Control Efficiency %: 95.00
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit limit Throughput= -.3,:2r'2L45631. Barrels (bbl) per year Requested Monthly Throughput= 188511 Barrels(bhl) per month
Potential to Emit (PTE) Volume Loaded =
Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating= 3 m2B B5 Barrels (bbl) per year
Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year = 3054258 scf/year
Actual heat content of waste gas routed to combustion device=
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routedtocombustion device =
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
The state default emissions factors may be used to estimate emissions.
/�.Hii`.�%iA'l'�,t7iA.
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-
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i iw: 7„.w
av
f
�i.w.a.,avr ,//7/fr.,„,/,/,,tig„ .r,
o�..
�
,.
Hydrocarbon Loadout
Pollutant
Pollutant
Uncontrolled
Controlled
(Ib/bbi(
(Ib/bbl)
(Volume
Loaded)
(Volume Loaded)
0.2360
MMEM
0.0008
0.0000
0.0000
0.0000
0.0002
0.0000
0.0030
Control Device
Uncontrolled
(Ib/MMBtu)
Uncontrolled
(lb/bbl)
(Volume
Loaded)
0.0000
0.0000
0.0000
0.0000
0.0000
(waste heat combusted(
0.0680:,"'
0.3100
Emission Factor Source
Emission Factor Source
Section OS - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tom/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0
261.91
261.91
13.10
261.91
13.10
2224
0.00
0.00
0.00
0.00
0.00
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
Ob./year( (lbs/year)
Requested Permit Um its
Uncontrolled Controlled
(lbs/year) (Ibs/Year)
Benzene
Toluene
Ethylbenzene
xyiene
n -Hexane
224TMP
910
910
96
910
46
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7990
7990
400
7990
400
0
0
0
0
0
9 of 16
I:\Oil & Gas Public Notice \18WE0437\18W E0437.PAAlsm
Hydrocarbon Loadout Emissions Inventory
Section 06- Regulatory Summary Analysis
Regulation 3, Parts A, B
RACE- Regulation 3,•Part B, Section III.D.2.a
(See regulatory applicability worksheet for detailed analysis)
Source requires APEN, Is permit exempt
RAC( does not apply
Section 07- Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
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 0R -Technical Analysis No
Section 09 - inventor,/ SCC Coding and Emissions Factors
AIRS Point If
011
Fracas lf SCC Code
O1 4-06-00732 Crude Oil: Submerged Loading Normal Service (0=0.6)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 b/1,000 gallons transferred
PM2.5 0.00 0 b/1,000 gallons transferred
50x 0.00 0 b/1,000 gallons transferred
NOx - 0.00 0 b/1,000 gallons transferred
V0C 5.6 95 b/1,000 gallons transferred
CO 0.00 o b/1,000 gallons transferred
Benzene 0.01 95 6/1,000 gallons transferred
Toluene 0.00 95 b/1,000 gallons transferred
Ethylbenzene 0.00 95 b/1,000 gallons transferred
Xylene 0.00 95 b/1,000 gallons transferred
n -Hexane 0.09 95 b/1,000 gallons transferred
224 TMP 0.00 95 b/1,000 gallons transferred
10 of 16 I:\OII & Gas Public Notice \18WE0437\18W E0437.PAxlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Re, lotion 3 Parts A and B- APEN and Permit Requirements
(Source Is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.O.l.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 8, Section II.D.1.1)?
3. is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
fgdb"s,
(You have Indicated that source Is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY (Regulation 3, Part A, Section 0.0.1.0)?
2. Is the loadout located at an exploration an4 production site (e.g., well pad) (Regulation 3, Part B, Section I1.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs( of crude oil per day on an annual average bass?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5.- Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part e, Section 11.D.2)?
(Source requires APEN, is permit exempt
7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section l ll.D.2.a)?
RACT does not apply
Disclaimer
• This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act, its implementing
regulations, and Air quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'recommend,"may,"'should,"and 'can,'is
intended to describe APCO interpretations and recommendations. Mandatory terminology such as 'must' and 'required" are intended to describe controlling requirements under the terms of the Clean Air
Act end Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
ROAM
x t >.'. s.
Go to next
Go to then
Go to next
Go to next
Go to next
The loadou
The loadou
Separator Venting Emissions Inventory
013 Separator Venting
'Facility AIRS ID:
County
9D8t} 3
Plant
013;:
Point
Section 02- Equipment Description Details
Detailed Emissions Unit Description:
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter afgr asY
Gas meter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput = 0:0:. MMscf per year
Requested Permit Umit Throughput = 20.0, MMscf per year
Requested Monthly Throughput = 2 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
20 MMscf per year
Secondary Emissions- Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL of
liquids throughput:
Section 04- Emissions Factors & Methodologies
Description
Helium
Weight %
CO2
N2
methane
ethane
._____._.__..... _...._.
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
Total
VOC Wt %
0.00
0.00
Btu/scf
scf/bbl
Ib/Ib-mol
Displacement Equation
Ex=COMW axo/C
12 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Separator Venting Emissions Inventory
Pollutant
Pollutant
Section 05 - Emissions Inventory
Separator Venting
Uncontrolled
(lb/MMscf)
Controlled
(lb/MMscf)
35420.0000
150.0000
68.0000
0.0000
18.4000
660.0000
0.0000
1771.0000
7.5000
3.4000
0.0000
0.9200
33.0000
0.0000
Primary Control Device
Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
Uncontrolled
lb/MMscf
0.0075....
0.0006.._.....
0.0680
0.3100
(Gas Throughput)
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
. Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
sox
NOx
VOC
CO
0.12
0.12
0.12
0.12
0.12
0.00
0.00
0.00
0.00
0.00
0.01
0.01
0.01
0.01
0.01
1.07
1.07
1.07
1.07
1.07
354.20
354.20
17.71
354.20
17.71
4.88
4.88
4.88
4.88
4.88
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
3000
3000
150
3000
150
1360
1360
68
1360
68
0
0
0
0
0
368
368
18
368
18
13200
13200
660
13200
660
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.0,
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07- Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Source requires a permit
Source is subject to Regulation 7, Section XVI1.B.2, G
The control device for this separator is subject to Regulation 7, Section XVII.B.2.e
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor 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 installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 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
13 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Separator Venting Emissions Inventory
14 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxIsm
Separator Venting Emissions Inventory
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process # SCC Code
013 01 3-10-001-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 11.74 0 lb/MMSCF
PM2.5 11.74 0 lb/MMSCF
SOx 0.93 0 lb/MMSCF
NOx 107.10 0 lb/MMSCF
VOC 35420.00 95 lb/MMSCF
CO 488.25 0 Ib/MMSCF
Benzene 150.00 95 Ib/MMSCF
Toluene 68.00 95 Ib/MMSCF
Ethylbenzene 0.00 95 lb/MMSCF
Xylene 18.40 95 Ib/MMSCF
n -Hexane 660.00 95 lb/MMSCF
224 TMP 0.00 95 lb/MMSCF
15 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B. APEN and Permit Requirements
'Source is in the Nen-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section Il.D.1.a)7
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than Sn TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.D.3)?
'Not enough Information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)?
Yes..<........
Source requires a permit
Colorado Regulation 7 Section XVII
1. Was the well newly constructed, hydraulically fractured, or recompleted on or after August 1,2014?
'Source is subject to Regulation T, Section X011.5.2, G
Section XV11.B.2 — General Provisions for Air Pollution Central Equipment and Provender of Emissions
Section XVII.G - Emissions Control
Alternative Emlulona Control (Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device (i.e., not the primary control device) that is not enclosed?
(The control device for this separator is subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e — Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis 3 contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change orsubstitute 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„ ifs implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend,"'may,"should," and 'Sen,'is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'most' and "required" are intended to describe controlling requirements under the terms of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Source Req
Source Req
The control
CDPHE
Permit number:
Date issued:
Issued to:
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
CONSTRUCTION PERMIT
18WE0441 Issuance: 1
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
High Point Operating Corporation
Anschutz Equus Farms 4-62-33 NWNW
123 9D8D
NWNW SEC 33 T4N R62W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
FLARE001
013
Open Flare
Open Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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.qov/pacific/cdphe/other-air-permittinq-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.qov/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
COLORADO
; Air Pollution Control Division
Page 1 of 7
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 4he 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:
Equipment ID
AIRS
Point
Tons per Year
Emission
T e
Type
PM2.5
NOX
VOC
CO
FLARE001
013
0.0
0.7
17.8
2.4
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to
calculate limits.
Facility -wide emissions of each individual hazardous air pollutant 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.)
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
FLARE001
013
Open Flare
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
COLORADO
Air Pollution Control Division
Page 2 of 7
SEP-1
001
Natural Gas Venting
20 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. 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 open flare covered by this permit has been approved as an alternative emissions control device
under Regulation Number 7, Section XVI1.B.2.e. The open flare must 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 open flare, or by other
convenient means approved by the Division, determine whether it is operating properly. This open
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 & 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. 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
COLORADO
Air Pollution Control Division
Page 3 of 7
16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or
other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five (5)
tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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.
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 I I. 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.
COLORADO
Air Pollution Control Division
Page 4 of 7
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:
Kirk Bear
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to HighPoint Operating Corporation
COLORADO
Air Pollution Control Division
Page 5 of 7
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder 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.
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(lb/yr)
FLARE
013
Benzene
71432
3000
150
Toluene
108883
1360
68
Xylenes
1330207
368
18
n -Hexane
110543
13200
660
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year (Ib/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission
Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/MMscf
Source
NOx
100.0
AP -42
CO
84.00
AP -42
VOC
35420
promax
71432
Benzene
150
promax
108883
Toluene
68.0
promax
1330207
Xylene
18.4
promax
110543
n -Hexane
660
promax
Note
The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
COLORADO
Air Pollution Control Division
Page 6 of 7
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAP
PSD
Synthetic Minor Source of: VOC, HAP
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
COLORADO
Air Pollution Control Division
Page 7 of 7
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Kirk Sear
Package 3: 378539
Received Date: 4/24/2018
Review Start Date: 8/13/2018
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment? oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? .y
If yes, for what pollutant? O Carbon Monoxide (CO)
H ighpaint Operating Corporationn
123
9D8D
Anschutz Equus Farms
NWNW quadrant of Section 33, Township 4N, Range 62WW
Weld County
Section 02 - Emissions Units In Permit Application
Particulate Matter (PM)
Quadrant
Section
Township
Range
62W
NWNW
Ozone (NOx & VOC)
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
009
GelridensateTank
OTK101-115
Yes
18WE0437
1
Yes
Permit Init€al.:
Issuance' "
010
Produced Water Tank
WTK101-WTK103
Yes
18WE0438
1
Yes
Permit Initial.
Issuance
011
€€quid Loading
TL001
Yes
18WE0439
1
yes
Permit Initial
Issuance'::..
013
Separator Venting :
FLARE001
Yes
18WE0441
1
yes:
Permit Initial
Issuance ?
Section 03 - Description of Project
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? ; Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? !Nc
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
yes
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
J
❑ ❑✓
Is this stationary source a major source? No
If yes, explain what programs and which pollutants here 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD)
❑❑❑❑❑ ____
Colorado Air Permitting Project
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
❑ ❑ ❑ ❑
Condensate Storage Tank(s) Emissions Inventory
009 Condensate Tank
Facility AIRs ID:
County
9D80 t;�vrgt39
Plant Pin
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput = - 2,663,478.1 Barrels (bbl) per year
Potential to Emit (PTE) Condensate
Throughput =
2,663,478. Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
Requested Monthly Throughput = 226213 Barrels (bbl) per month
2,663,478 Barrels (bbl) per year
.2,663,478;: Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = Stu/scf
Volume of waste gas emitted per BBL of liquids
produced —.acf/bbl
Actual heat content of waste gas routed to combustion device
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
Emission Factors
Condensate Tank
Pollutant
VOC
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
0::510)...'...
0.0007:.
0.0005
(Condensate
Throughput)
0.0255
0.0000
0.0000
0.0000
0.0000
0.0003
0.0000
Control Device
Benzene
Toluene
Ethylbenzene
Xylene
000
n -Hexane
224 TMP
• 4.0053
Pollutant
Uncontrolled Uncontrolled
.(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
PM25
NOz
CO
0.0000
0.0000
0.0000
0.0000
U.d680.,1
03100
Section 05 - Emissions Inventory
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
.(tans/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
VOC
PM10
PM2.5
NOx
CO
679.2
679.2
34.0
679.2
34.0
5768
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual.Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1891
1891
95
1891
95
1252
1252
63
1252
63
0
0
0
0
0
400
400
20
400
20
14116
14116
706
14116
706
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII.C-F
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section X11.0
Regulation 7, Section XVII.B, Cl, C.3
Storage tank is subject to Regulation 7, Section XVII, B, Cl & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation B, Part E, MACF Subpart HH ,
Storage Tank is not subject to MALT HH
0.9455
0.6259
0.0000
0.1998
7.0582
0.0000
0.0473
0.0313
0.0000
0.0100
0.3529
0.0000
See regulatory applicability worksheet for detailed analysis)
3 of 16
I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 -Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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 drawn at the
facility being permitted? This sample should be considered representative which generally means site -specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it maybe appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point # Process it SCC Code
009 01
Uncontrolled
Pollutant Emissions Control % Units
Factor
PM10 0.00 0 lb/1,000 gallons condensate throw
PM25 0.00 0 lb/1,000 gallons condensate throw
NOx 0.00 0 lb/1,000 gallons condensate throw
VOC 12.1 95 lb/1,000 gallons condensate throu
CO 0.00 0 lb/1,000 gallons condensate throu
Benzene 0.02 95 lb/1,000 gallons condensate throu
Toluene 0.01 95 lb/1,000 gallons condensate throe
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throu
Xylene 0.00 95 lb/1,000 gallons condensate throu
n -Hexane 0.13 95 lb/1,000 gallons condensate throw
224 TMP 0.00 95 lb/1,000 gallons condensate throw
4 of 13 l:\Oil & Gas Public Notice \18W E0437\18WE0437.PA.xlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Re' u lotion 3 Parts A and B - APEN and Permit Requirements
Source Is In the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part rt, Section II.0.1.a)?
2. Is the construction date (service date) prior -to 12/30/2002 and not modified after 12/31/2002 (See PS Marne 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greaterthan lO TPY (Regulation 3, Part 0,Section 11.03)?
Not enough information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation3, Part A, Section 11.0.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1,14 and Section 2for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOT greater than 5TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section 100.2)?
Source requires a permit
Colorado Regulation 7, Section 311.0-F
1. Is the storage tank located in the &hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. sthis storage tank located at an ail and gas exploration and production operation, natural gas compressor station or natural gas drip station?
3. Is this storage tank located upstream of a natural gas processing plant?
'Storage tank Is subject to Regulation 7, Section XII.C-F
Section 101.01 —General Requirements for Air Pnik,lon Control Equipment —Prevention of Leakage
Section 311.03 —Emission Ertimatisn Procedures
Section ]UID—Emisslons Control Requirements
Section NIX —Monitoring
Section XII.F— Recordkeeping and Reporting
Colorado Regulation 7. Section 011.0
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does the storage tank exhibit 'Flash'(e.g. storing non-atabilhed liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC?
Storage Tank is not subject to Regulation 7, Section OII.G
Section XII.G2- Emissions Control Requirements
Section 01.01 —General Requirements for Air P01031on Control Equipment —Prevention of Leakage
Section IIII.C2— Emission Estimation Procedures
Colorado Regulation 7, Section lMl
1. Is this tank located at a transmission/storagefaciihyl
2. is this condensate storage tanks looted at an oil and gas exploration and production operation, well production fadlity[, natural gas compressor stations or natural gas processing plant?
3. Is this condensate storagetank a fixed roof storage tank?
4. Are uncontrolled actual emissions` of this storage tank equal to or greaterthan 6 tons per year VOC7
'Storage tank Is subject to Regulation 7, Section XVII, R, .8. C.3
Section %VII.B—General Provisions for Air Pollutlan Control Equipment and Prevention of Emissions
Section XVII.[.1- Emissions Control and Monitoring Provisions
Section XVII.Cs - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilBed" liquids?
'Storage tank is subject to Regulation', Section 3VII.C.2
Section %VII.C2 - Capture and Monitoring forltoage Tanks fitted with Air Pollution Conlon Equipment
40 CFR. Part 60. Subpart Kb. standards of Performance for Volatile Organic Liquid Storage Vessels
1. N the individual storage vessel capacity greaterthan or equal to 75 cubic meters (m) (`472 RBIs)?
2. floes Me storage vessel meet the following exemption In 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.074m' ('10,4,100 BBL] used for petroleum' or condensate stored,processed, ortreated prior to custody tra nsfef m defined in 60.1116?
3. Was this condensate storage tank constructed, reconstructed, or modifNd(see definitions 40 CFR, 60.2) after luly 23, 1964?
4. Does the tank meet the definition of"storage veer' in 60.1116?
5. Does the storage vessel store a'volatile organic liquid (VOL)". as defied in 60.1116?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 2049 kPe 1`29.7 psi) and without emissions to the atmosphere (6o.110b(d)(2))7; or
b. The design opacity's greaterthan or equal to 151 ms (-950 BBL] and stores a liquid with a maximum true vapor pressure` less than 35 kPa (6o.110b(b))?; or
c The design capacity is greaterthan or equal to 75 Ma (-472 BBL] but less than 151 ma (-950 BBL] and stores a liquid with a maximum true vapor pressure` less than 15.0 koa(60.110b(b))?
'Storage Tank is not subject to 'IMPS Kb
SubpartA, General Provisions
4601126- Emissions Control Standards for VOC
460.1.13b-Testingand Procedures
160515b -Reporting and Recordkeeping Requirements
410.016b- Monitoring of Operations
40 CFR. Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Produceon, Transmission and Distribution
1. Is this condensate storage vessel located et a facility In the onshore o5 and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this condensate storage vessel constructed, remnstmeted, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Are potential VOC emeslonss from the indfvidualatorage vessel greater than or equal to 6 tons per year?
4. Does this condensate Manage vessel meet the definition of "storage vessel"' per 6054307
5. Is the stooge vessel subject to and controlled in accordance with requirements forstora a vessels In 40 CFR Part 60 Subpart Kb or40 CFR Part 63Sub part Hu?
'Storage Tank Is not subject to NIPS O000
Subpart A, General Provisions per 1605425 Table 3
4605395- Emissions Control Standards for VOC
4605413 -Testing and Procedures
4665395(8)- Notification, Reporting and Recordkeeping Requirements
4605416(o). Coverand Closed Vent System Monitoring Requirements
466.5417- Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subjectto NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subjectto NSPS 0000 per 6o.5365(e)(2) even
If potential VOC emissions drop below 6 tons per year)
4O CFR, Pert 63. Subpart MALT HH, Oll and Gas Production Facilities
1. Is the storagetenk located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility thatprocesses, upgrades orstor. hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that process., upgrades or Moro natural gas priorto the point at which natural gas enters the natural gas transmission and storageiource category or Is delivered to a final end user' (63.760(a)(3))7
2. Is the tank bated at a facility that is major for HAPs?
3. Do. the tank meet the definition of -storage vessel'[ In 63.761?
4. noes the tank meet the definition of"storage vessel with the potentialtorflash emissions. per 63.761?
5. is Me tank sub)ett to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 00007
'Storage Tank Is not subject to MAR HH
Subpart A, General provisions per463.764 (a) Table 2
463.766 - Emissions Control Standards
163.773 Monitoring
463.774- Recordkeeping
463.775 -Reporting
RACT Review
RACT review Is required If Regulation? does not apply AND If the Mk is in the nonaoalnmentarea Ifthe rank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicabcfity of certain requirements of the Clean Air Ad, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply toe particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations. the language of the statute or regulation will control. The use of non -mandatory language such as 'recommend 'may," "should,' and'oan,' is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and "required' are intended to descdhe controlling requirements under the leans of the Clean Air Act
and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of dself.
Yes
yes
Yes
no
yes
MEM
Yes
Neaa
Mqiir
Source Req
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'K; rs96,xxx,�
Storage Tar
Produced Water Storage Tank(s) Emissions Inventory
010 Produced Water Tank
Facility AIRs ID:
123 iv ,D,g4
County Plant
Pain
Section 02- Equipment Description Details
Detailed Emissions Unit three 400 barrel produced water tanks
Description:
Emission Control Device enclosed combustor
Description:
Requested Overall VOC & HAP Control
Efficiency %:
95 ,
Section 03 -Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
Requested Permit Limit Throughput =
1,510,000; Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating =
1,500,010! Barrels (bbl) per year
Requested Monthly Throughput= 127397 Barrels (bbl) per month
Potential to Emit (PTE) Produced Water
Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquids
produced= ,.,.._.'..._.._.3,..3::.x... scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
500 005: Barrels (bbl) per year
Btu/scf
0 MMBTU per year
0 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors Produced Water Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Produced
(Produced Water Water
Throughput) Throughput)
Emission Factor Source
VOC
:452
.0009,
Benzene
Toluene
Ethylbenzene
Pollutant
02'.
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
Emission Factor Source
PM10
Section 05- Emissions Inventory
0.0000
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ns/month)
VOC
PM10
PM2.5
NOx
CO
39.0
39.0
2.0
39.0
2.0
331
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TM
1335
1335
67
1335
67
360
360
18
360
18
0
0
0
0
0
0
0
-0
0
0
1035
1035
52
1035
52
0
0
0
0
0
0.6675
0.1800
0.0000
0.0000
0.5175
0.0000
0.0334
0.0090
0.0000
0.0000
0.0259
0.0000
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
(See regulatory applicability worksheet for detailed analysis)
6 of 16
I:\Oil & Gas Public Notice\18WE0437\18WE0437.PA.xlsm
Produced Water Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
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 water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to
use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing.
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
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point it
010
Process # SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 Ih/1,000 gallons liquid throughput
PM2.5 0.00 0 lb/1,000 gallons liquid throughput
NOx 0.00 0 lb/1,000 gallons liquid throughput
VOC 1.2 95 lb/1,000 gallons liquid throughput
CO 0.00 0 lb/1,000 gallons liquid throughput
Benzene 0.02 95 lb/1,000 gallons liquid throughput
Toluene 0.01 95 lb/1,000 gallons liquid throughput
Ethylbenzene 0.00 95 lb/1,000 gallons liquid throughput
Xylene 0.00 95 lb/1,000 gallons liquid throughput
n -Hexane 0.02 95 lb/1,000 gallons liquid throughput
224 IMP 0.00 95 lb/1,000 gallons liquid throughput
7 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Produced Water Storage Tank Regulatory Analysis Worksheet
Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb.
Colorado Be:oiation 3 Parts A and B-APEN and Permit Requirements
(source is in tire Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 WY (Regulation 3, Part A, Section 11.0.1.a)?
2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.3)?
'You have indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than l TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the operator claiming less than 1% crude oil and Is the tank located at a non-commercial facility for processing of and gas wastewater? (Regulation 3, Part B, Section ll.D.1.M)
3. Are total facility uncontrolled VOC emissions greater than 2IPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Parte, Section 11.0.2)? _
'Source requires permit
Colorado Regulation 7, Section ](VII
1. Is this tank located at a transmission/storage facility?
2. Is this produced water storage tank' located at an oil and gas exploration and production operation , wet production facility', natural gas compressor stations or natural gas processing plant?
3. Is this produced water storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC?
'Storage tank is subject to Regulation 7, Section XV II, B, C.1 & C.3
Section XVII.0 —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the produced water storage tank contain only "stabilized. liquids? If no, the following additional provisions apply.
'Storage tank is subject to Regulation 7, Section XVII.C.2
Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution
1. Is this produced water storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this produced water storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August23, 2011 and September 13, 2015?
3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this produced water storage vessel meet the definition of "storage vessel"' per 60.5430?
'Storage Tank is not subject to NIPS 0000
Subpart A, General Provisions per 160.5425 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: ti a storage vessel is previously determined to be subject to NSPS OOOO due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NSPS OOOO per 60.5365(e)(2)
even If potential VOC emissions drop below 6 tons per year]
RACT Review
RACE review Is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. ti the tank meets both criteria, then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and uroumstances. This document does not change or substitute for any law,
regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its
implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation 'al control. The use of non -mandatory language such as -recommend,' "may,"
'should,"and "can,'is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and "required'are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
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Hydrocarbon Loadout Emissions inventory
011 Liquid Loading
Facility Al Rs ID:
:»1? I l�3 111233
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this load out controlled?
Collection Efficiency:
Control Efficiency:
Requested Overall VOC & HAP Control Efficiency%: 95.00
Section 03 - Processine Rate Information far Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit Umit Throughput = ,�2.219.r565i; Barrels (bbl) per year Requested Monthly Throughput= 180511 Barrels (bbl) per month
,,,,,W64,t,219,566, Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating = 2;219,565 Barrels (bbl) per year
1-5;444.2.M9,56.6; Barrels (bbl) peryeer
EMIBtu/scf
Volume of waste gas emitted per year = 3054258 scf/year
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas muted to combustion device =
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Des the hydrocarbon liquid loading operation utilize submerged fill?
Emission Factors
Pollutant
Hydrocarbon Loadout
Uncontrolled
(lb/bbl)
(Volume Loaded)
VOC 0:236
Benzene 0:00
Toluene
Ethylbenzene
Xylene
n-Hmane
224 IMP
0.0036:
Control Device
Controlled
(lb/bbl)
(Volume
Loaded)
0.0118
0.0000
0.0000
0.0000
0.0000
0.0002
0.0000
Uncontroiled Uncontrolled
Pollutant (Ib/MMBtu)
(waste heat combusted)
Section 05 Emissions Inventory
0 MMBTU per year
0 MMBTU per year
0 MMBTU per year
The state default emissions factors may be used to estimate emissions.
Emission Factor Source
(lb/bbl) Emission Factor Source
(Volume
loaded)
0.0000
0.0000
0.oboo
Potential to Emit
Actual Emissions
Requested Permit Limits
Requested Monthly Limits
Criteria Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
Controlled
(tons/year)
(tons/year) (tom/year)
(tom/year) (tans/year)
(lbs/month)
PM10
0.00
0.00
0.00
0.00
0.00
0
PM25
0.00
0.00
0.00
0.00
0.00
0
sox
0.00
0.00
0.00
0.00
0.00
0
NOx
0.00
0.00
0.00
0.00
0.00
0
VOC
261.91
261.91
13.10
261.91
13.10
2224
CO
ODD
0.00
0.00
0.00
0.00
0
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(Ibs/year)
(Ibs/year) (Ibs/year)
(lbs/year) (Ibs/year)
Benzene
910
910
46
910
46
Toluene
0
0
0
0
0
Ethylhenzene
0
0
0
0
0
Xylene
0
- 0
0
0
0
n -Hexane
7990
7990
400
7990
400
224TMP
0
0
0
0
0
9 of 16
I:\OII & Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Hydrocarbon Loadout Emissions Inventory
Section 06 - Regulatory SummaryAnalysts
Regulation 3, Parts A, B
RACE - Regulation 3, Part B, Section III.D.2.a
(See regulatory applicability worksheet for detailed analysis)
Source requires APEN, is permit exempt
RACT does not apply
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company request a control device ef0dency greater than 95% for a Rare 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 09 - Inventory SCC Coding and Emissions Factors
AIRS Point Ir
011
Process #
01
SCC Code
4-06-001-32 Crude Oil: Submerged Loading Normal Service (5=0.6)
Uncontrolled
Emissions
Pollutant FactorControl % Units
PM10 0.00 0 b/1,000 gallons transferred
PM2.5 0.00 0 6/1,000 gallons transferred
SOB 0.00 0 b/1,060 gallons transferred
NOx 0.00 0 b/1,000 gallons transferred
VOC 5.6 95 b/1,000 gallons transferred
CO 0.00 0 b/1,000 gallons transferred
Benzene 0.01 95 6/1,000 gallons transferred
Toluene 0.00 95 b/1,000 gallons transferred
Ethylbenxene 0.00 95 b/1,000 gallons transferred
Xylene 0.00 95 6/1,000 gallons transferred
n -Hexane 0.09 95 6/1,000 gallons transferred
224 TMP 0.00 95 6/1,000 gallons transferred
10 of 16 I:\Oil & Gas Public Notice \ 18WE0437 \18WE0437.PA.xlsm
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Re- ulatlon 3 Parts A and B - APEN and Permit Requirements
'Source Is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section 11.0.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 Buts) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)?
tau have Indicated that source is In the Non -Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greafer than 1TPY (Regulation3, Part A, Section 11.0.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 8, Section 11.0.1.1)1
3. Is the loadout operation loading less than 10,000 gallons (238 0B1,$) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbk per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.1.2)?
Source requires APEN, is permit exempt
7. RACT Am uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section lll.D.2.a)?
RACT does not apply
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis d 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„ ifs implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," Way" "should,"and -can,'is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and 'required `are intended to describe controlling requirements under the tens of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
MAIM
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WINZA
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The loadou
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Separator Venting Emissions Inventory
013 Separator Venting
Facility AIRs ID:
123, 8D8Lf„iv.`
County Plant
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Description:
emergency flare
emergency flare
Emission Control Device Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter NvtEtr2
Gas meter
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions - Separator
Actual Throughput =
20O MMscf per year
20.0 MMscf per year
Requested Permit Limit Throughput =
Requested Monthly Throughput = 2 MMscf per month
Potential to Emit (PTE) Throughput =
Process Control (Recycling)
Equipped with a VRU:
Is VRU process equipment:
20 MMscf per year
Secondary Emissions - Combustion Device(s) for Air Pollution Control
Separator Gas Heating Value:
Volume of waste gas emitted per BBL o
liquids throughput:
Section 04- Emissions Factors & Methodologies
Description
MW
Weight
Helium
CO2
N2
methane
ethane
propane
isobutane
n -butane.
isopentane
n -pentane
cydopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
CB* Heavies
Total
VOC Wt %
0.00
0.00
Btu/scf
scf/bbl
Ib/Ib-mol
Displacement Equation
Ex=Q' MW•Xx/C
12 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsw
Separator Venting Emissions Inventory
Emission Factors
Separator Venting
Pollutant
Uncontrolled Controlled
(lb/MMscf) (lb/MMscf)
(Gas Throughput)
(Gas Throughput)
VOC
35420,0000
1771.0000
Benzene
Toluene
150.0000
68.0000
0.0000
18.4000
660.0000
7.5000
3.4000
0.0000
0.9200
33.0000
0.0000
Ethylbenzene
Xylene
n -Hexane
224 TNIP
0.0000
Pollutant
Primary Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(Waste Heat
Combusted)
0.0075 ,
Emission Factor Source
lb/MMscf Emission Factor Source
PM10
PM2.5
SOx
(Gas Throughput)
0:0006,-'.;
0AG80 11£££777.
0:3100)Aiiil'.
0.9
NOx
CO
107.1
488.3
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
PM10
PM2.5
sox
NOx
VOC
CO
0.12
0.12
0.12
0.12
0.12
0.00 `
0.00
0,00
0,00
0.00
0.01
0.01
0.01
0.01
0.01
1.07
1.07
1.07
1.07
1.07
354.20
354.20
17.71
354.20
17.71
4.88
4.88
4.88
4.88
4.88
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
3000
3000
150
3000
150
1360
1360
68
1360
68
0
0
0
0
0
368
368
18
368
18
13200
13200
660
13200
660
0
0
0
0
0
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Section XVII.B, G
Regulation 7, Section XVII.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Using Gas Throughput to Monitor Compliance
Source requires a permit
Source is subject to Regulation 7, Section XVII.0.2, G
The control device for this separator is subject to Regulation 7, Section XVll.8,2.e
Does the company use site specific emission factors based on a gas sample to estimate emissions?
This sample should represent the gas outlet of the equipment covered under this AIRs ID, and should have been collected within one year of the application received date. However, if
the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an alder site -specific sample.
If no, the permit will contain an "Initial Testing Requirement" to collect a site -specific as sample from the equipment being permitted and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this application.
Are facility -wide permitted emissions of VOC greater than or equal to 90 tons per year?
If yes, the permit will contain:
-An "Initial Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor analysis to demonstrate that the
emission factors are less than or equal to the emissions factors established with this application.
-A "Periodic Testing Requirement" to collect a site -specific gas sample from the equipment being permitted and conduct an emission factor 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 installed and operational upon startup of this point? No
If no, the permit will contain a condition that requires the operator to calculate gas throughput using the liquid throughput until the meter is installed and operational (not
to exceed 180 days). This condition will use the "Volume of waste gas emitted per BBL of liquids throughput" (scf/bbl) value in section 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
13 of 15 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Separator Venting Emissions Inventory
You have indicated above that the monitored proce
pa
ame
following questions do not require an answer.
14 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PAxlsm
Separator Venting Emissions Inventory
Section 08 Technical Analysis Notes
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
013
Process# SCC Code
01 3-10-00'i-60 Flares
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 11.74 0 Ib/MMSCF
PM2.5 11.74 0 Ib/MMSCF
SOx 0.93 0 Ib/MMSCF
NOx 107.10 0 Ib/MMSCF
VOC 35420.00 95 lb/MMSCF
CO 488.25 0 lb/MMSCF
Benzene 150.00 95 lb/MMSCF
Toluene 68.00 95 lb/MMSCF
Ethylbenzene 0.00 95 Ib/MMSCF
Xylene 18.40 95 Ib/MMSCF
n -Hexane 660.00 95 lb/MMSCF
224 TMP 0.00 95 Ib/MMSCF
15 of 16 I:\Oil & Gas Public Notice \18WE0437\18WE0437.PA.xlsm
Separator Venting Regulatory Analysis Worksheet
Colorado Re ulatlon 3 Parts A and a -APEN and Permit Requirements
'Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section Il.D.1.a)?
2. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10TPY (Regulation 3, Part B, Section 11.D.3)?
Not enough Information
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY (Regulation 3, Part A, Section 110.1.5)?
2. Are total facility uncontrolled VOC emissions from the greater then 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.021?
Ioource requires a permit
Colorado Regulation 7, Section XVII
I. Was the well newly constructed, hydraulically fractured, ormcompleted on or after August 1, 2014?
'Source is subject to Regulation 7, Section XVII.B.2, G
Section XVII.B.2— General Provisions far Air Pollution Control Equipment and Prevention of Emissions
Section XVII.G - Emissions Control
Alternative Emissions Control (Optional section)
a. Is this separator controlled by a back-up or altemate combustion device (I.e., not the primary control device) that is not enclosed?
'The control device fumble separator is subject to Regulation 7, Section XVII.B.2.e
Section XVII.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is
not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law,
regulation, or any otherlegally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as'mcbmmend,"may,' "should,' and -can,' is
intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must- and -required' are intended to describe controlling requirements under the terns of the Clean Air
Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Vey Source Req
Yes _____:Source Req
f'S S'`-,' 1The control
Condensate Storage Tank(s) APEN -
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.Rov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number:
O VtIE0+3-7
AIRS ID Number: 123 / 9D8D / 0 Q q
[Leave blank unless APCD has already assigned a permit?t and AIRS ID]
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Anschutz Equus Farms 4-62-33 NWNW
Site Location: NWNW Sec 33 T4N R62W
40.35587, -104.46682
Mailing Address:
(Include Zip Code) 1099 18th Street, Suite 2300
Denver, Colorado 80202
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Marsha Sonderfan
Phone Number: 303-312-8524
E -Mail Address2: CDPHE_Corr@hpres.com
' Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 07/2017
378532
COLORADO
1 I O_ low
„v=.,�,,.
Permit Number: AIRS ID Number: 123 / 9D8D /
[Leave blank unless APCD has already assigned a permit" and AIRS ID]
Section 2 - Requested Action
E NEW permit OR newly -reported emission source
Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
- OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: This APEN includes emissions from combustion of
flashing/working&breathing emissions in the site enclosed combustors.
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:
Condensate Storage
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
1/24/2018
hours/day 7 days/week
0 Exploration a Production (EEtP) site
52
weeks/year
❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
Fl
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
GI
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
II
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.0012
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)•
805 series rules? If so, submit Form APCD-105.
Yes
No
GI
Are you requesting a 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
0
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
2
COLORADO
Department al Publ.
Permit Number:
AIRS ID Number: 123 / 9D8D /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Condensate Throughput:
From what year is the actual annual amount?
Average API gravity of sales oil: 37.4 degrees
❑ Internal floating roof
Tank design: 11 Fixed roof
Requested Annual Permit Limit4
(bbl/year)
2,663,478
RVP of sales oil: 8.1
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
OTK101-115
15
6,000
01/2018
01/2018
Wells Serviced by this Storage Tank or Tank Battery5 (EFtP Sites On
y)
API Number
Name of Well
Newly Reported Well
See Attached Addendum (Form APCD-212)
El
Ej
El
0
0
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward
❑ Horizontal
0 Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
El Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
COLORADO
3 , ,W =
Permit Number: AIRS ID Number: 123 / 9D8D /
[Leave btank unless APCD has already assigned a permit r and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: 3 x 550 Mscfd MMBtu/hr
Type: Make/Model: Cimarron/84"
Requested Control Efficiency: %
Manufacturer Guaranteed Control Efficiency: %
Minimum Temperature: Waste Gas Heat Content: -2052 Btu/scf
Constant Pilot Light: ❑ Yes ❑ No Pilot Burner Rating: 0.473 MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? -7 psig
Describe the separation process between the well and the storage tanks: Liquids from 3 -phase separators
are directed to two 2 -phase heater treaters further reducing pressure. Liquids from the heater treaters are directed
to three VRTs. Liquids from the VRTs are directed to the 15 storage tanks.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
4 I a-COLORADO
i°`""k
Permit Number:
AIRS ID Number: 123 / 9D8D /
[Leave blank unless APCD has already assigned a permit u and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustor
95
NOx
CO
HAPs
Enclosed Combustor
95
Other:
From what year is the following reported actual annual emissions data?
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc) )
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
0.51
lb/bbl
ProMax 4.0
675.60
33.78
NOx
100 / 0.068
IlatklMscf,IUMMBtu
AP -42 1.4 & 13.5
—
3.59
CO
84 / 0.31
Ib/MM6U,ib/MMBtu
AP -42 1.4 & 13.5
—
13.64
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions?
(Pounds/year)
Benzene
71432
0.00071
lb/bbl
ProMax 4.0
Toluene
108883
0.00047
lb/bbl
ProMax 4.0
Ethylbenzene
100414
—
--
—
Xylene
1330207
0.00015
lb/bbl
ProMax 4.0
n -Hexane
110543
0.0053
lb/bbl
ProMax 4.0
2,2,4-
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
,COLORADO
Mnt
Permit Number:
AIRS ID Number: 123 / 9D8D /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
A A. Zr - t5
Signature of Legally Authorized Person (nba vendor or consultant) Date
Marsha Sonderfan
EHS Specialist
Name (print)
Title
Check therappropriate 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)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit For more information or assistance call:
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1 530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 07/2017
Hydrocarbon Liquid Loading APEN - Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source. 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:
l( WE 643 1 AIRS ID Number: 123 /9D80 / Q I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Company equipment Identification: TL001
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Anschutz Equus Farms 4-62-33 NWNW
Site Location: NWNW Sec 33 T4N R62W
40.35587, -104.46682
Mailing Address:
(Include Zip Code) 1099 18th Street, Suite 2300
Denver, Colorado 80202
E -Mail Address': CDPHE_Corr@hpres.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Marsha Sonderfan
Phone Number: 303-312-8524
'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-208 - Hydrocarbon Liquid Loading APEN - Rev 02/2017
378534
COLORADO
1 I
Permit Number:
AIRS ID Number: 123 /9D8D/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2- Requested Action
E NEW permit OR newly -reported emission source
E Request coverage under construction permit
❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of $25O must be submitted
along with the APEN Filing fee. -
- OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name
❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below)
- OR
• APEN submittal for update only (Blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes:
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:
Condensate Tank Truck Loadout
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
01/ 24 /2018
/ /
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?
Does this source load gasoline into transport vehicles?
Is this source located at an oil and gas exploration and production site?
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Does this source splash fill less than 6750 BBL of condensate per year?
Does this source submerge fill less than 16308 BBL of condensate per year?
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
❑ Yes ❑ No
❑ Yes E No
❑ Yes ❑✓ No
❑ Yes ❑ No
E Yes ❑Q No
❑ Yes E No
❑ Yes (] No
AVCOLORADO
A 2 I
Permit Number:
AIRS ID Number: 123 /9D8D/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume
Loaded4:
2,219,565
Bbl/yr
Actual Volume
Loaded:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
This product is loaded from tanks at this facility into: truck
(eg, "rail tank cars" or "tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature
of bulk liquid loading:
°F
True Vapor
Pressure
Psia ® 60 °F
Molecular weight of
displaced vapors
Lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume
Loaded5:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Bbl/yr
Actual Volume
Loaded:
Bbl/yr
Product Density: Lb/ft3
Load Line Volume:
ft3/truckload Vapor Recovery Line Volume
ft3/truckload
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 3 I
COLORADO
Department P.Wc
nv,� 6 t.r.vtppm.pt
Permit Number:
AIRS ID Number: 123 /9D813
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 5 - Geographical Information
Geographical Coordinates
(Latitude/Longitude or UTM)
_Operator.Temp.
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
('F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
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
Section 6 - Control Device Information
❑ Loading occurs using a vapor balance system:
Requested Control Efficiency
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: 3 x 550 Mscfd MMBtu/hr
Type: 3 x Endosed Combustors Make/Model: Cimarron/84"
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
95
98
Waste Gas Heat Content ,-2052 Btu/scf
Constant Pilot Light: ❑Q Yes ❑ No Pilot burner Rating 0.473 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
AVCOLORADO
Permit Number:
AIRS ID Number: 123 /9D8lie'
[Leave blank unless APCD has already assigned,a permit ft 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 yes, describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SOX
NO,,
CO
VOC
Enclosed Combustor
95
HAPs
Enclosed Combustor
95
Other:
❑ Using State Emission Factors (Required for GP07) VOC
E Condensate 0.236 Lbs/BBL
❑ Crude 0.104 Lbs/BBL
Benzene n -Hexane
0.00041 Lbs/BBL 0.0036 Lbs/BBL
0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
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
5
Emission Limit(s)
Uncontrolled
(Tons/year)
Controlled5
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
NO,,
0.068
lb/MMBtu
AP-42,CH 13.5
-
0.37
VOC
0.236
lb/bbl
GP07
261.91
13.10
CO
0.31
lb/MMBtu
AP-42,CH 13.5
-
1.67
Benzene
0.00041
lb/bbl
GP07
0.46
0.023
Toluene
Ethylbenzene
Xylenes
n -Hexane
0.0036
lb/bbl
GP07
4.00
0.20
2,2,4-
Trimethylpentane
Other:
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
5Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017
COLORADO
5De,rtment amp
Permit Number:
AIRS ID Number: 123 /9D8i
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will
be operated in full compliance with each condition of the applicable General Permit.
JiukAstLo-
Signature of Legally Authorized Person (not a vendor or consultant)
Marsha Sonderfan
2 -��
Date
EHS Specialist
Name (print) Title
Check th appropriate box to request a copy of the:
aft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General
Permit registration fee of $250 as applicable to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
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
COLORADO
Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 02/2017 6 I
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for 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.Rov/cdphe/apcd.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: IC� NE 044 I AIRS ID Number: 1 23 / 908D/ Q 1 -5
[Leave blank unless APCD has already assiened a permit-- and AIRS ID]
Company equipment Identification: FLARE001
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': HighPoint Operating Corporation
Site Name: Anschutz Equus Farms 4-62-33 NWNW
Site Location: NWNW Sec 33 T4N R62W
40.35587, -104.46682
Mailing Address:
(Include Zip Code) 1099 18th Street, Suite 2300
Denver, Colorado 80202
E -Mail Address': CDPHE_Corr@hpres.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Marsha Sonderfan
Phone Number: 303-312-8524
'Please 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-211 - Natural Gas Venting APEN - Rev 03/2017
OLORADO
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378536
Permit Number:
AIRS ID Number: 123 i9D8D /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 2- Requested Action
El 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:
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:
Flare to control emissions from
emergency or non -routine operations events
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
/ /
04 / 20 / 2018
❑ 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
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
days/week weeks/year
O Yes ❑ No
❑ Yes ❑✓ No
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Permit Number:
AIRS ID Number: 123 /9D8D /
[Leave blank unless ARCD has already assigned a permit = and AIRS ID]
Section 4 - Process Equipment Information
❑r 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?
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑r Yes
❑ No
Maximum Vent
Rate:
SCF/hr
Vent Gas
Heating Value:
1575
BTU/SCF
Requested:
20
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 (mote %)
25.31
VOC (Weight %)
Benzene (mole %)
0.0497
Benzene (Weight %)
Toluene (mole %)
0.0327
Toluene (Weight %)
Ethylbenzene (mole %)
0.0030
Ethylbenzene (Weight %)
Xylene (mole %)
0.0066
Xylene (Weight %)
n -Hexane (mole %)
.2939
n -Hexane (Weight %)
2,2,4-Trimethylpentane
0.0007
(mole %) (Weight
2,2,4 Trimethylpentane
%)
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX & n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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Permit Number:
AIRS ID Number: 123 /908D/
[Leave blank unless P.PCD des already a_siened a permit = and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
Operator
Stack ID No.
Discharge Height
Above Ground Level
(Feet)
Temp.
(SF)
Flow Rate
(ACFM)
Velocity
(ft/sec)
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
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: MMBtu/hr
Type: TBD Make/Model: TBD
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
98
%
Waste Gas Heat Content 1575 Btu/scf
Constant Pilot Light: ❑ Yes ❑ No Pilot burner Rating
0.472 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
Form APCD-211 -Natural Gas Venting APEN - Rev 03/2017
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Permit Number:
AIRS ID Number: 123 / 9D8Di
[Leave blank unless APCD has already assigned a permit 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 yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
Sox
NOx
VOC
FLARE001 - Controls Venting Emissions
95
CO
HAPs
FLARE001 - Controls Venting Emissions
95
Other:
From what year is the following reported actual annual emissions data?
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
7.6
Ib/MMscf
AP -42, Ch1.4
—
0.015
SOx
0.60
Ib/MMscf
AP -42, Ch1.4
—
0.0012
NOx
p
100, 0.068
Ib/MMscf,lb/MMBtu
AP -42, Ch1A8135
0.69
VOC
17.71
tons/MMscf
SS Analysis
354.23
17.71
CO
84, 0.31
Ib/MMscf.Ibfl UBtu
—
2.38
Benzene
0.075
tons/MMscf
SS Analysis
. 1.5
0.075
Toluene
0.034
tons/MMscf
SS Analysis
0.67
0.034
Ethylbenzene
Xylenes
0.0092
tons/MMscf
SS Analysis
0.18
0.0092
n -Hexane
0.33
tons/MMscf
SS Analysis
6.67
0.33
2,2,4-
Trimethylpentane
Other:
5 Requested values wilt become permit limitations. Requested timit(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-211 -Natural Gas Venting APEN - Rev 03/2017
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Permit Number:
AIRS ID Number: 123 / 9D8D /
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct.
LAM r-- 15S
Signature of Legally Authorized Person (not a vendor or consultant)
Marsha Sonderfan
Date
EHS Specialist
Name (please print) Title
Check th appropriate box to request a copy of the:
po graft permit prior to issuance
2 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-B 1
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-211 -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
COLORADO
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