HomeMy WebLinkAbout20183544.tiff CDPKE COLORADO
co Department of Public
Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150 O St
PO Box 758 RECEIVED
Greeley, CO 80632
NOV 0 5 2010
October 30, 2018
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On November 1, 2018, the Air Pollution Control Division will begin a 30-day public notice period for
Longs Peak Resources, LLC - Oxnard East. A copy of this public notice and the public comment packet
are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
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
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CDPHE Air Pollution Control Division
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co ', Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Longs Peak Resources, LLC - Oxnard East - Weld County
Notice Period Begins: November 1, 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: Longs Peak Resources, LLC
Facility: Oxnard East
Well production facility
SESE SEC 31 T12N R66W
Weld County
The proposed project or activity is as follows: New 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 source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0563 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:
Christopher Kester
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
Acjv COLORADO
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Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer: Christopher Kester
Package#: 381755
Received Date: 5/16/2018
Review Start Date: 4/24/2018
Section 01-Facility Information
Company Name: Longs Peak Resources,LLC Quadrant Section Township Range
County AIRS ID: 123 SESE _ .31 12N 66
Plant AIRS ID: 6FC4
Facility Name:
Physical
Address/Location: SESE quadrant of Section 31,Township 12N,Range 66W
County: Weld County
Type of Facility: Exploration:&Productions Well Pad
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area?
If yes,for what pollutant? Carbon Monoxide(CO) ❑ Particuete Matter(PM) ❑ Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Emissions Self Cert Engineering
AIRS Point tt Emissions Source Type Equipment Name Permit# Issuance# Action
Control? Required? Remarks
Per€nit Initial
001 Produced Water Tank PW Yes GP08 1 No. Issuance
- - _ Permit Initial
O02 Natural Gas RICE GEN1 Yes 18WE0563 1 -;Yes.. - Issuance
t P€rrot Inii t,,,".:2..003 .Natural Gas RICE GEN2 Yes. 18WE0564 1 Yes fssnance •�-
. - APEN Required
. /'Permit
O04 • Liquid Loading LOAD No 13W50565-XP 1 Yes E tempt'_
• ,Permit.lnitiaf
O05 Crude Ott Tank TANKS Yes 18WE0566 1 ,Yes. Issuance
,..: .> Permit Initial
006 .. Separator Venting SEPARATOR .Yes ;.18WE0567 1 .-Yes.. :..:'. Issuance • .•
l •
Section 03-Description of Project
New synthetic minor well production facility.
Section 04-Public Comment Requirements
Is Public Comment Required? yes
If yes,why? ReqeeslIngyxsthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement:
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide StationarySource Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 Nox CO VOC�PM2I�.S PM1I0�TSP HAPs
Prevention of Significant Deterioration(PSD) q q q !-�.I El L-I
Colorado Air Permitting Project
Title V Operating Permits(OP) Ill _ OHO ❑ ❑ ❑
Non-Attainment New Source Review(NANSR)
Is this stationary source a major source?
If yes,explain what programs and which pollutants hers 5O2 NOx CO VOC PM2.5-PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) _ _ ❑ ❑
Title V Operating Permits(OP)
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Non-Attainment New Source Review(NANSR)
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CONSTRUCTION PERMIT
Permit number: 18WE0563 Issuance: 1
Date issued:
Issued to: Longs Peak Resources, LLC
Facility Name: Oxnard East
Plant AIRS ID: 123/9FC4
Physical Location: SESE SEC 31 T12N R66W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
One (1) Doosan/PSI, D0146TIC, SN: EEZOG-
401354, natural gas-fired, turbo-charged Non-selective
GEN1 002 aspirated, 4SRB reciprocating internal catalytic reduction
combustion engine, site rated at 362 (NSCR) system and
horsepower. This unit is used for power air-fuel ratio control
generation.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Doosan/PSI, DO146TIC engine in accordance with
the permanent replacement provision of the Alternate Operating Scenario (AOS), included
in this permit as Attachment A.
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, y
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the
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�Divis; n artu th . rmitt • source is a violation of Air Quality Control
Com ss QC ula •n Numd-r 3, Part B, Section III.G.1. and can result in the
revo ti o he er
2. in h a' day :0) 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 construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in
this permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
GEN1 002 --- 3.5 2.5 7.0 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
4 CDPtf£ COLORADO
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twel F total, s lcul bas-j on the previous twelve months' data. The permit
hold= s alcu ctu d issi oft s each month and keep a compliance record on
site 7 a l al f ld fic ith sit-.responsibility for Division review.
7. - e n s ble r-'sw 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 'II.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
GEN1 002 Non-selective catalytic reduction (NSCR) NOx and CO
system and air-fuel ratio control
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
GEN1 002 Consumption of natural gas as a fuel 18.7 MMscf
Fuel consumption shall be measured by one of the following methods: individual engine
fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of
operation; or manufacturer-provided fuel consumption rate.
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 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 AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, II I.E.) (State only enforceable)
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal
operation of the source. During periods of startup, process modification, or
adjustment of control equipment visible emissions shall not exceed 30% opacity for
more than six minutes in any sixty consecutive minutes. Emission control devices
subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions.
(Reference: Regulation No. 1, Section II.A.1. Et 4.)
D COLORADO
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11. 4,This •u - su•i to i4 odo requirements of Regulation No. 2. (State only
enfoel-
OPE' IN IN N CE `EQ REMEN 5
12. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (OEM) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to the OEM plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
13. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
14. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
15. 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.
nrxs COLORADO
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GENE® .L TEL A C ON
16. pe y nts I 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.
17. 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.
18. 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.
19. 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.
20. 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.
21. 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.
22. 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.
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Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Longs Peak Resources, LLC
cliv COLORADO
CO Aar Pollution Control Division
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Notes . Pe it r at h tim his p mit issuance:
1) T per t l is r qui d t,~ p feev or the processing time for this permit. An invoice
fo,•them fe t b iss d er the ' -rmit is issued. The permit holder shall pay the
wi 3 0 of t - voice. 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 Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
002 Formaldehyde 50000 585 585
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission
rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees
based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
NOx 2.21 lb/MMBtu 1.00 g/hp-hr AP-42
CO 3.72 lb/MMBtu 2.00 g/hp-hr AP-42
VOC 0.70 g/hp-hr 0.70 g/hp-hr Manufacturer
50000 Formaldehyde 0.0205 lb/MMBtu 0.0205 lb/MMBtu AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 9000 Btu/hp-hr,
a site-rated horsepower value of 362, and a fuel heat value of 1533 Btu/scf.
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
at COLORADO
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A'7N exp ra . sate f. `each Visions point associated with this permit. For any
qustionre�. t ng a 1 fic .( pi,ation,•ate call the Division at (303)-692-3150.
7) T enef e . s ee to I C", Part I, Subpart JJJJ—Standards of Performance for
S ary ••r $ io - al C• stion Engines (See January 18, 2008 Federal
Register posting - effective March 18, 2008). This rule has not yet been incorporated into
Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart
is available on the EPA website at: http://www.epa.Rov/ttn/atw/area/fr18ja08.pdf
8) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for
Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January
18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008
amendments to include requirements for area sources and engines < 500 hp located at major
sources have not yet been incorporated into Colorado Air Quality Control Commission's
Regulation No. 8. A copy of the complete subpart is available on the EPA website at:
http://www.epa.gov/ttn/atw/area/fr181a08.pdf Additional information regarding area
source standards can be found on the EPA website at:
http://www.epa.govittn/atw/area/arearules.htnnl
9) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC
PSD Synthetic Minor Source of:
VOC
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart KKKK
NSPS Part 60, Appendix A - Appendix I
Appendixes
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
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TTA' HMENT A:
AL R T VE OPERATING SCENARIOS
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0 a !J h INT L COMBUSTION ENGINES
October 12, 2012
1. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas
fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3,
Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and
Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural
requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement
performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
1.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine
maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent
replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month
period. "Permanent"is defined as in the same service for more than 90 operating days in any 12 month period. The
90 days is the total number of days that the engine is in operation. If the engine operates only part of a day, that
day shall count as a single day towards the 90 day total.The compliance demonstrations and any periodic monitoring
required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit
(including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within
30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with
NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5)years and made available to the Division upon request.
The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the
engine(s) that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and
serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all
Applicability Reports required under section 1.1.2 and make them available to the Division upon request.
1.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set
forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different
manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary
replacement engine complies with all permit limitations and other requirements applicable to the existing engine.
Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2.
1.1.2 The owner or operator may permanently replace the existing engine with another engine with the same
manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement
engine complies with all permit limitations and other requirements applicable to the existing engine as well as any
new applicable requirements for the replacement engine. Measurement of emissions from the permanent
replacement engine and compliance with the applicable emission limitations shall be made as set forth in section
1.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and
horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement
engine within 14 calendar days of commencing operation of the replacement engine.The APEN shall be accompanied
by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
nrx� COLORADO
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operati • scen 'o . .stalls f• . •erm n€replasI ent engine, and a copy of the relevant Applicability Reports
for the placefen one. Ex. Apply: lily
Report can .- f. n. ;.t h ;es:/ .l. ado.g /pacific/cdphe/alternate-operating-scenario-aos-reporting-
forms is s it sh be_ cco s ani-, by a cer ii,ication from the Responsible Official indicating that "based
on thz ati.rata. �a or reaso r inquiry, the statements and information included in the
submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine
that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for_review of information
submitted to the Division in regard to any permanent engine replacement.
1.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable
Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing
requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified
by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test
conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for
another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX)and carbon monoxide (CO)emissions in the exhaust from
the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation
of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer
Monitoring Protocol (ver March 2006 or newer) as found on the Division's web site at:
https://www.colorado.gov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests
shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever
applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year (8760), whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd ® 15%O2) that the existing unit is currently subject to or the replacement engine will
be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned
Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence
of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and
CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable
analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be
considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test
indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline.
1.3 Applicable Regulations for Permanent Engine Replacements
1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B§ II.D.2
A COP COLORADO
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rut Page 10 of 12
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All per ..nent pl W t ent, that e locate. "n an area that is classified as attainment/maintenance or
nonatt.t, ment us %•°',ly Rea Ava I- Cont?it Technology (RACT) for the pollutants for which the area is
attain «nt/m. to n or no t att..-<men.. Note th.'/both VOC and NOX are precursors for ozone. RACT shall be
applied .r an; eve .f e =ssio s of t* pot Cant for ,y ich the area is in attainment/maintenance or nonattainment,
exce•, a .ws:
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and
to NOX and 5O2, as precursors to PM10, if the potential to emit of NOX or SO2 exceeds 40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal
combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
SO2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or
less of total sulfur per 100 standard cubic feet.
1.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State-Only
conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the
applicable control requirements specified in Regulation No. 7, section XVI, as specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst
and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to
reduce emissions.
The above emission control equipment shall be appropriately sized for the engine and shall be operated and
maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2.
Emission Standards: Section XVII.E- State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the
date listed in the table below shall operate and maintain each engine according to the manufacturer's written
instructions or procedures to the extent practicable and consistent with technological limitations and good
engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards
required in the table below:
Construction or Emission Standards in G/hp-hr
Max Engine HP Relocation Date
NOx CO VOC
January 1, 2008 2.0 4.0 1.0
100<Hp<500 January 1, 2011 1.0 2.0 0.7
July 1, 2007 2.0 4.0 1.0
500≤Hp July 1, 2010 1.0 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
1.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
DA COLORADO
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A perm ent r Ala m engi at is .n 'factur on or after 7/1/09 for emergency engines greater than 25
hp, 7/t!008 a less 00 h• _ 4 /200 or engines greater than or equal to 500 hp except for lean
burn e Lines ef at t or ual 50S'' p .nd le- than 1,350 hp, and 1/1/2008 for lean burn engines greater
than or qual j 5 hp d le' tha 1,351 hp are su ject to the requirements of 40 CFR Part 60, Subpart JJJJ. An
analy• o , rP"rig,an- urting requirements for the permanent engine replacement
shall be included in the Applicability Reports required under Condition 1.1.2. Any testing required by the NSPS is in
addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing
required by this AOS under Condition 1.2,if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 1.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of
the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of
Regulation No. 6(i.e.,the date that the source is first relocated to Colorado becomes equivalent to the manufacture
date for purposes of determining the applicability of NSPS JJJJ requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine
subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an
additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8
(which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of
Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ.
1.3.4 Reciprocating internal combustion engine (RICE)MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR
Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the
permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any
testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the
MACT can serve as the testing required by this AOS under Condition 1.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition 1.2.
1.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new
emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced
construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that
is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing
onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation.
em is COLORADO
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jilltik
Ai • tlut- -' Co of Division
D eartr nt Ribitc He tip&Environment
CONSTRUCTION PERMIT
Permit number: 18WE0564 Issuance: 1
Date issued:
Issued to: Longs Peak Resources, LLC
Facility Name: Oxnard East
Plant AIRS ID: 123/9FC4
Physical Location: SESE SEC 31 T12N R66W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
One (1) Doosan/PSI, D081 NA, SN: EEPOF-
301291, natural gas-fired, naturally Non-selective
GEN2 003 aspirated, 4SRB reciprocating internal catalytic reduction
combustion engine, site rated at 106 (NSCR) system and
horsepower. This unit is used for power air-fuel ratio control
generation.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another Doosan/PSI, D081 NA engine in accordance with the
permanent replacement provision of the Alternate Operating Scenario (AOS), included in
this permit as Attachment A.
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, y
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the
GDA E COLORADO
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Divis n artu : th-� .-rmittt• source is a violation of Air Quality Control
Com ss QC ula •n Numr-r 3, Part B, Section III.G.1. and can result in the
revo ti o he er
2. in h a - day °':0) 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 construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in
this permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO, VOC CO Type
GEN2 003 --- 1.1 --- 2.1 Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant 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
COP E COLORADO
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twel �!PtotalalculL1 baszle4, on the previous twelve months' data. The permit
•hold= s : alcul. ctu issi/ s each month and keep a compliance record on
site I art: l al feld fic ith sit responsibility for Division review.
7. "e e - +n 6 °$s ble it'+w shall be operated and maintained with the
emissions control equipment as listed in order to reduce emissions to less than or equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
GEN2 003 Non-selective catalytic reduction (NSCR) NOx and CO
system and air-fuel ratio control
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
GEN2 003 Consumption of natural gas as a fuel 7.9 MMscf
Fuel consumption shall be measured by one of the following methods: individual engine
fuel meter; facilty-wide fuel meter attributed to fuel consumption rating and hours of
operation; or manufacturer-provided fuel consumption rate.
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 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 AIRS ID point number (e.g. 123/4567/890) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, II I.E.) (State only enforceable)
10. Visible emissions shall not exceed twenty percent (20%) opacity during normal
operation of the source. During periods of startup, process modification, or
adjustment of control equipment visible emissions shall not exceed 30% opacity for
more than six minutes in any sixty consecutive minutes. Emission control devices
subject to Regulation 7, Sections XII.C.1.d or XVII.B.2.b shall have no visible emissions.
(Reference: Regulation No. 1, Section II.A.1. Et 4.)
4 cnex COLORADO
CO ,y; Air Pollution Control Division
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11. 1This .0 - su. - to -f odo : requirements of Regulation No. 2. (State only
enfo e
•
OPE' _ IN . IN N CE":EQ REMEN
12. 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
13. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
14. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
15. 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.
41/4 co COLORADO
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GENE' ,LT AC ON
16. 411,4: y nts :• 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.B. upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
17. 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.
18. 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.
19. 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.
20. 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.
21. 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.
22. 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.
or► COLORADO
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fr
By: fr
ris ph r Ke - r 47,
ne
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Longs Peak Resources, LLC
i CDPHE COLORADO
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Page 6 of 12
s
Notes • Pe ` it ' r at; h tim- . his p mit issuance:
1) T per t '"t r is r qur d t•p. fee.t,or the processing time for this permit. An invoice
fo the ' fe, l b.` iss d . `er the :,-rmit is issued. The permit holder shall pay the
i - wi 3 o ® ' of t "- voice. 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 emission levels contained in this permit are based on the following emission factors:
Point 003:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
N0x 2.21 lb/MMBtu 1.00 g/hp-hr AP-42
CO 3.72 lb/MMBtu 2.00 g/hp-hr AP-42
V0C 0.70 g/hp-hr 0.70 g/hp-hr Manufacturer
50000 Formaldehyde 0.0205 lb/MMBtu 0.0205 lb/MMBtu AP-42
Emission factors are based on a Brake-Specific Fuel Consumption Factor of 12928 Btu/hp-
hr, a site-rated horsepower value of 106, and a fuel heat value of 1533 Btu/scf.
5) 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.
6) This engine is subject to 40 CFR, Part 60, Subpart JJJJ—Standards of Performance for
Stationary Spark Ignition Internal Combustion Engines (See January 18, 2008 Federal
Register posting - effective March 18, 2008). This rule has not yet been incorporated into
Colorado Air Quality Control Commission's Regulation No. 6. A copy of the complete subpart
is available on the EPA website at: http://www.epa.gov/ttn/atw/area/fr18ja08.pdf
7) This engine is subject to 40 CFR, Part 63, Subpart ZZZZ - National Emission Standards for
Hazardous Air Pollutants for Reciprocating Internal Combustion Engines. (See January
18, 2008 Federal Register posting - effective March 18, 2008). The January 18, 2008
amendments to include requirements for area sources and engines < 500 hp located at major
sources have not yet been incorporated into Colorado Air Quality Control Commission's
tz £ COLORADO
0 or
« Air Pollution Control Division
Page 7 of 12
R ulati . A of ' - omp to subpart is available on the EPA website at:
ht �:// w Rov/ tw/ e /fr1 : .08.pdf Additional information regarding area
so ce s n rds n be ound on the EPA website at:
, a to -a/art, .les.html
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC
PSD Synthetic Minor Source of:
VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart KKKK
NSPS Part 60, Appendix A - Appendix I
Appendixes
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
co HE COLORADO
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L(TTAHMENTA:
AL R T VE 0 ERATING SCENARIOS
0 INT L COMBUSTION ENGINES
October 12, 2012
1. Alternative Operating Scenarios
The following Alternative Operating Scenario (AOS) for the temporary and permanent replacement of natural gas
fired reciprocating internal combustion engines has been reviewed in accordance with the requirements of
Regulation No. 3., Part A, Section IV.A, Operational Flexibility-Alternative Operating Scenarios, Regulation No. 3,
Part B, Construction Permits, and Regulation No. 3, Part D, Major Stationary Source New Source Review and
Prevention of Significant Deterioration, and it has been found to meet all applicable substantive and procedural
requirements. This permit incorporates and shall be considered a Construction Permit for any engine replacement
performed in accordance with this AOS, and the owner or operator shall be allowed to perform such engine
replacement without applying for a revision to this permit or obtaining a new Construction Permit.
1.1 Engine Replacement
The following AOS is incorporated into this permit in order to deal with an engine breakdown or periodic routine
maintenance and repair of an existing onsite engine that requires the use of either a temporary or permanent
replacement engine. "Temporary" is defined as in the same service for 90 operating days or less in any 12 month
period. "Permanent"is defined as in the same service for more than 90 operating days in any 12 month period. The
90 days is the total number of days that the engine is in operation. If the engine operates only part-of a day, that
day shall count as a single day towards the 90 day total.The compliance demonstrations and any periodic monitoring
required by this AOS are in addition to any compliance demonstrations or periodic monitoring required by this permit.
All replacement engines are subject to all federally applicable and state-only requirements set forth in this permit
(including monitoring and record keeping).
The results of all tests and the associated calculations required by this AOS shall be submitted to the Division within
30 calendar days of the test or within 60 days of the test if such testing is required to demonstrate compliance with
NSPS or MACT requirements.
Results of all tests shall be kept on site for five (5)years and made available to the Division upon request.
The owner or operator shall maintain a log on-site and contemporaneously record the start and stop date of any
engine replacement, the manufacturer, date of manufacture, model number, horsepower, and serial number of the
engine(s)that are replaced during the term of this permit, and the manufacturer, model number, horsepower, and
serial number of the replacement engine. In addition to the log, the owner or operator shall maintain a copy of all
Applicability Reports required under section 1.1.2 and make them available to the Division upon request.
1.1.1 The owner or operator may temporarily replace an existing engine that is subject to the emission limits set
forth in this permit with an engine that is of the same manufacturer, model, and horsepower or a different
manufacturer, model, or horsepower as the existing engine without modifying this permit, so long as the temporary
replacement engine complies with all permit limitations and other requirements applicable to the existing engine.
Measurement of emissions from the temporary replacement engine shall be made as set forth in section 1.2.
1.1.2 The owner or operator may permanently replace the existing engine with another engine with the same
manufacturer, model, and horsepower engines without modifying this permit so long as the permanent replacement
engine complies with all permit limitations and other requirements applicable to the existing engine as well as any
new applicable requirements for the replacement engine. Measurement of emissions from the permanent
replacement engine and compliance with the applicable emission limitations shall be made as set forth in section
1.2.
An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model and serial number and
horsepower of the permanent replacement engine shall be filed with the Division for the permanent replacement
engine within 14 calendar days of commencing operation of the replacement engine.The APEN shall be accompanied
by the appropriate APEN filing fee, a cover letter explaining that the owner or operator is exercising an alternative
DP" COLORADO
CO Air Pollution Control Division
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ti
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operati - • 'sceno d i stall',` ,;.erm n repla ment engine, and a copy of the relevant Applicability Reports
for the . placeen ne. Ex F Appl ity
Reporti can i s f n t h ado.O /pacific/cdphe/alternate-operating-scenario-aos-reporting-
forms is s it sh be,c:cco ' ani by a cers ication from the Responsible Official indicating that "based
on thg=zsr ati =E or reaso res inquiry, the statements and information included in the
submittal are true, accurate and complete".
This AOS cannot be used for permanent engine replacement of a grandfathered or permit exempt engine or an engine
that is not subject to emission limits.
The owner or operator shall agree to pay fees based on the normal permit processing rate for review of information
submitted to the Division in regard to any permanent engine replacement.
1.2 Portable Analyzer Testing
Note: In some cases there may be conflicting and/or duplicative testing requirements due to overlapping Applicable
Requirements. In those instances, please contact the Division Field Services Unit to discuss streamlining the testing
requirements.
Note that the testing required by this Condition may be used to satisfy the periodic testing requirements specified
by the permit for the relevant time period (i.e. if the permit requires quarterly portable analyzer testing, this test
conducted under the AOS will serve as the quarterly test and an additional portable analyzer test is not required for
another three months).
The owner or operator may conduct a reference method test, in lieu of the portable analyzer test required by this
Condition, if approved in advance by the Division.
The owner or operator shall measure nitrogen oxide (NOX) and carbon monoxide (CO) emissions in the exhaust from
the replacement engine using a portable flue gas analyzer within seven (7) calendar days of commencing operation
of the replacement engine.
All portable analyzer testing required by this permit shall be conducted using the Division's Portable Analyzer
Monitoring Protocol (ver March 2006 or newer)as found on the Division's web site at:
https://www.colorado.Rov/pacific/sites/default/files/AP Portable-Analyzer-Monitoring-Protocol.pdf
Results of the portable analyzer tests shall be used to monitor the compliance status of this unit.
For comparison with an annual (tons/year) or short term (lbs/unit of time) emission limit, the results of the tests
shall be converted to a lb/hr basis and multiplied by the allowable operating hours in the month or year(whichever
applies) in order to monitor compliance. If a source is not limited in its hours of operation the test results will be
multiplied by the maximum number of hours in the month or year (8760), whichever applies.
For comparison with a short-term limit that is either input based (lb/mmBtu), output based (g/hp-hr) or
concentration based (ppmvd @ 15% O2) that the existing unit is currently subject to or the replacement engine will
be subject to, the results of the test shall be converted to the appropriate units as described in the above-mentioned
Portable Analyzer Monitoring Protocol document.
If the portable analyzer results indicate compliance with both the NOX and CO emission limitations, in the absence
of credible evidence to the contrary, the source may certify that the engine is in compliance with both the NOX and
CO emission limitations for the relevant time period.
Subject to the provisions of C.R.S. 25-7-123.1 and in the absence of credible evidence to the contrary, if the portable
analyzer results fail to demonstrate compliance with either the NOX or CO emission limitations, the engine will be
considered to be out of compliance from the date of the portable analyzer test until a portable analyzer test
indicates compliance with both the NOX and CO emission limitations or until the engine is taken offline.
1.3 Applicable Regulations for Permanent Engine Replacements
1.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B§ II.D.2
8" COLORADO
CO Air Pollution Control Division
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All per 5,.nent, -pl - ; t enn" that e;ocate 'n an area that is classified as attainment/maintenance or
nonatt.`" ment :us & y Rea a, Ava Cont l Technology (RACT) for the pollutants for which the area is
attain «nt/m tee n or n att .men N to th both VOC and NOX are precursors for ozone. RACT shall be
applied"..r an•j'eve .f eittssia s of t pot Cant for hich the area is in attainment/maintenance or nonattainment,
exce. .ws: at=
In the Denver Metropolitan PM10 attainment/maintenance area, RACT applies to PM10 at any level of emissions and
to NOX and SO2, as precursors to PM10, if the potential to emit of NOX or S02 exceeds 40 tons/yr.
For purposes of this AOS, the following shall be considered RACT for natural gas fired reciprocating internal
combustion engines:
VOC: The emission limitations in NSPS JJJJ
CO: The emission limitations in NSPS JJJJ
NOX: The emission limitations in NSPS JJJJ
5O2: Use of natural gas as fuel
PM10: Use of natural gas as fuel
As defined in 40 CFR Part 60 Subparts GG (5 60.331) and 40 CFR Part 72 (5 72.2), natural gas contains 20.0 grains or
less of total sulfur per 100 standard cubic feet.
1.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State-Only
conditions).
Control Requirements: Section XVI
Any permanent replacement engine located within the boundaries of an ozone nonattainment area is subject to the
applicable control requirements specified in Regulation No. 7, section XVI, as specified below:
Rich burn engines with a manufacturer's design rate greater than 500 hp shall use a non-selective catalyst
and air fuel controller to reduce emission.
Lean burn engines with a manufacturer's design rate greater than 500 hp shall use an oxidation catalyst to
reduce emissions.
The above emission control equipment shall be appropriately sized for the engine and shall be operated and
maintained according to manufacturer specifications.
The source shall submit copies of the relevant Applicability Reports required under Condition 1.1.2.
Emission Standards: Section XVII.E- State-only requirements
Any permanent engine that is either constructed or relocated to the state of Colorado from another state, after the
date listed in the table below shall operate and maintain each engine according to the manufacturer's written
instructions or procedures to the extent practicable and consistent with technological limitations and good
engineering and maintenance practices over the entire life of the engine so that it achieves the emission standards
required in the table below:
Construction or Emission Standards in G/hp-hr
Max Engine HP Relocation Date
NOx CO VOC
January 1, 2008 2.0 4.0 1.0
100<Hp<500 January 1, 2011 1.0 2.0 0.7
July 1, 2007 2.0 4.0 1.0
500≤Hp July 1, 2010 1.0 2.0 0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
1.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
44, DA s ' COLORADO
CO Air Pollution Control Division
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1,
A perm',; ent r.: Ala engi at isLnfactur$ on or after 7/1/09 for emergency engines greater than 25 hp, 7/1008 •, i y 4 e - less . 00 h. /200 or engines greater than or equal to 500 hp except for lean
burn e :Lines at J t or ival 508 p b.nd lei than 1,350 hp, and 1/1/2008 for lean burn engines greater
than or equal 50i hp d le tha t hp are su 4 ect to the requirements of 40 CFR Part 60, Subpart JJJJ. An
analyi u : , . ica 2i7.,•:. o _,0':°', r — ng, anclieporting requirements for the permanent engine replacement
shall be included in the Applicability Reports required under Condition 1.1.2. Any testing required by the NSPS is in
addition to that required by this AOS. Note that the initial test required by NSPS Subpart JJJJ can serve as the testing
required by this AOS under Condition 1.2,if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 1.2.
Note that under the provisions of Regulation No. 6. Part B, section I.B. that Relocation of a source from outside of
the State of Colorado into the State of Colorado is considered to be a new source, subject to the requirements of
Regulation No. 6(i.e., the date that the source is first relocated to Colorado becomes equivalent to the manufacture
date for purposes of determining the applicability of NSPS JJJJ requirements).
However, as of October 1, 2011 the Division has not yet adopted NSPS JJJJ. Until such time as it does, any engine
subject to NSPS will be subject only under Federal law. Once the Division adopts NSPS JJJJ, there will be an
additional step added to the determination of the NSPS. Under the provisions of Regulation No. 6, Part B, § 1.8
(which is referenced in Part A), any engine relocated from outside of the State of Colorado into the State of
Colorado is considered to be a new source, subject to the requirements of NSPS JJJJ.
1.3.4 Reciprocating internal combustion engine (RICE)MACT: 40 CFR Part 63, Subpart ZZZZ
A permanent replacement engine located at either an area or major source is subject to the requirements in 40 CFR
Part 63, Subpart ZZZZ. An analysis of the applicable monitoring, recordkeeping, and reporting requirements for the
permanent engine replacement shall be included in the Applicability Reports required under Condition 2.1.2. Any
testing required by the MACT is in addition to that required by this AOS. Note that the initial test required by the
MACT can serve as the testing required by this AOS under Condition 1.2, if approved in advance by the Division,
provided that such test is conducted within the time frame specified in Condition 1.2.
1.4 Additional Sources
The replacement of an existing engine with a new engine is viewed by the Division as the installation of a new
emissions unit, not "routine replacement" of an existing unit. The AOS is therefore essentially an advanced
construction permit review. The AOS cannot be used for additional new emission points for any site; an engine that
is being installed as an entirely new emission point and not as part of an AOS-approved replacement of an existing
onsite engine has to go through the appropriate Construction/Operating permitting process prior to installation.
4 CDPHE COLORADO
co Air Pollution Control Division
Page 12 of 12
OP 1E
Aa � •
llut Co of Division
`t D .art nt• Pub(tc Huth&Ertvironment
CONSTRUCTION PERMIT
Permit number: 18WE0566 Issuance: 1
Date issued:
Issued to: Longs Peak Resources, LLC
Facility Name: Oxnard East
Plant AIRS ID: 123/9FC4
Physical Location: SESE SEC 31 T12N R66W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
TANKS 005 Four (4) 400 barrel fixed roof storage Enclosed Combustion
vessels used to store crude oil Device
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, y
submitting a Notice of Startup form to the Division for the equipment covered by this
permit. The Notice of Startup form may be downloaded online at
www.colorado.gov/pacific/cdphe/other-air-permitting-notices. Failure to notify the
Division of startup of the permitted source is a violation of Air Quality Control
Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the
revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation
or issuance of this permit, compliance with the conditions contained in this permit shall
be demonstrated to the Division. It is the owner or operator's responsibility to self-
certify compliance with the conditions. Failure to demonstrate compliance within 180
days may result in revocation of the permit. A self certification form and guidance on
eRE COLORADO
Air Pollution Control Division
Page 1 of 8
•
how -rtify; pli. as r$uired by this permit may be obtained online at
www= olr.•..go = cific/ .I, e/aii permit-self-certification. (Regulation Number 3,
Part It S ti' III .2
3. Ts pe s`. pi m .wne +' 'operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the
date on which such construction or activity was scheduled to commence as set forth in
the permit application associated with this permit; (ii) discontinues construction for a
period of eighteen months or more; (iii) does not complete construction within a
reasonable time of the estimated completion date. The Division may grant extensions
of the deadline. (Regulation Number 3, Part B, Section III.F.4.)
4. The operator 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. (Regulation
Number 3, Part B, Section II.A.4.)
)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO, VOC CO Type
TANKS 005 --- --- 13.1 2.3 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.
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.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
1 CthE COLORADO
CO Azr Pollution Control Division
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t.A En osed Combustion Device VOC and HAP
4
PRO MI O D •;t.
7. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Parameter Annual Limit
ID
TANKS 005 Crude Oil Throughput 69,905 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 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
8. 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)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. 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.
11. 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
tLl f COLORADO
O L O R Control Division CO 1 Page 3 of 8
effic: n� • .t le« •8% c ydro .rbons except where the combustion device has
it
been''''.;u•"-`6$', ed b; mit �iqr to y 1, 2014. The source shall follow the inspection
requ -e 'z nt.'.of Regul~ ion : umber , Section XVII.C.1.d. and maintain records of the
2-, .: -ct.., f• ri• f � year ,o. ade available to the Division upon request. This
control requirement must be met within 90 days of the date that the storage tank
commences operation.
12. 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 I* MAINTENANCE REQUIREMENTS
13. 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 O13M 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
14. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
15. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
16. 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.
4c6PHE COLORADO
Co t Air Pollution Control Division
n:� _ e•<< Page 4 of 8
• - ver t m is a nge i the owner or operator of any facility, process, or
a iw.y; or
�en A er ew •nt l equipment is installed, or whenever a different type of
•' ro1 - 'pm- ` ?faces 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
17. 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.
18. 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.
19. 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.
20. 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.
21. 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.
22. 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
cc�l~ COLORADO
f CO Air Pollution Control Division
u�3� ,� Page 5 of 8
Divis1nt4 ting esti can illation of the permit. Upon notification, annual
ee •, 'h l ter• ' e.
23. io g io _.f 1,e -rms of . permit °. of the provisions of the Colorado Air Pollution
-ven aye . tr.' . the re Lions 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:
Christopher Kester
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Longs Peak Resources, LLC
cnxe COLORADO
CO Air Pollution Control Division
Page 6 of 8
Notes o Perms it' r at h tim- Jhis p mit issuance:
1) Th. per t l is r qui d p. fee _"or the processing time for this permit. An invoice
fo the '= fe l b iss d . er the ermit is issued. The permit holder shall pay the
i e wit 3 ai§ o eat- w' of thb" voice. 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 Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
005 n-Hexane 110543 4544 227
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission
rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees
based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 005:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP-42
VOC 7.494 0.3747 Site Specific
110543 n-Hexane 0.065 0.00325 Emission Factors
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
CDP Hfi COLORADO
CO Air Pollution Control Division
Page 7 of 8
k
A' N ex i> ra ®ate f. each '.sions Joint associated with this permit. For any
qu stion re4 ,'ng a fic - ation .ate call the Division at (303)-692-3150.
7) T tt per it ` If t • re• ire ent to Cold a valid permit reflecting the storage tank and
. is e C• •o Oil and Gas Conservation Commission rule
805b(2)(A) when applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC
PSD Synthetic Minor Source of:
VOC
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart KKKK
NSPS Part 60, Appendix A - Appendix I
Appendixes
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
olt, COLORADO
CO Air Pollution Control Division
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C;HErj; AD
C 0 0
o ent of wittc Healy . Envlronr t
CONSTRUCTION PERMIT
Permit number: 18WE0567 Issuance: 1
Date issued:
Issued to: Longs Peak Resources, LLC
Facility Name: Oxnard East
Plant AIRS ID: 123/9FC4
Physical Location: SESE SEC 31 T12N R66W
County: Weld County
General Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
SEPARATOR 006 One (1) 2-phase high pressure separator Enclosed Combustion
Device
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, ty
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-
* SDP 4E COLORADO
CO i Air Pollution Control Division
Page 1 of 9
tify corn ce - «.nditions. to demo ompliance ithin 180
s may re' in •c. of the p -- -lf certi do orm and •j•ance on
to self. -rtify pli.A- as refired by 1---!Vs per may be obtainer •nline at
$ •toe. 'c/c• '19-rmit-s if (Regulatip•A._:•.!:per 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 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. Upon issuance of this permit, the operator shall install a flow meter to monitor and
record volumetric flow rate of natural gas vented from each separator covered by this
permit.
5. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self-certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO, VOC CO Type
SEPARATOR 006 --- --- 26.0 7.2 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.)
,, cor t COLORADO
�► ti Air Pollution Control Division
Page 2 of 9
jbm
VI 're
e P JçhneviceJi P utants
C rolled
SEPARATOR 006 Enclosed Combustion Device 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
Facility AIRS Process Parameter Annual Limit
Equipment ID Point
SEPARATOR 006 Natural Gas Venting 30.7 MMSCF
Compliance with the annual throughput limits shall be determined on a rolling twelve
(12) month total. By the end of each month a new twelve-month total is calculated
based on the previous twelve months' data. The permit holder shall calculate
throughput each month and keep a compliance record on site or at a local field office
with site responsibility, for Division review.
9. Upon issuance of this permit, the owner or operator shall continuously monitor and
record the volumetric flow rate of natural gas vented from the separator(s) using the
flow meter. The owner or operator shall use monthly throughput records to demonstrate
compliance with the process limits contained in this permit and to calculate emissions
as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g.
123/4567/001) shall be marked on the subject equipment for ease of identification.
(Regulation Number 3, Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7,
Section XVII.B.2. General Provisions (State only enforceable). If a flare or other
combustion device is used to control emissions of volatile organic compounds to comply
with Section XVII, it shall be enclosed; have no visible emissions during normal
operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that
an observer can, by means of visual observation from the outside of the enclosed flare
or combustion device, or by other convenient means approved by the Division,
determine whether it is operating properly. This flare must be equipped with an
operational auto-igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with
an operational auto-igniter upon installation of the combustion device;
COP HE COLORADO
43,
CO_ 9 Air Pollution Control Division
Page 3 of 9
• All cc,. •Usti •- installed >-f• J `b ay 1, 20 be equip with an
oper. ',flat . =o-i.x er by or ba 4 « `1, 2016, after the next bustion
dev' =plann . shut•c, n, whi `:ever co t first.
13. -s'e•arator corgi"-• • thi pe`tn ' ubje =g n , Section . ` (State
Only). On or after August 1, 2014, gas coming off a separator, produced during normal
operation from any newly constructed, hydraulically fractured, or recompleted oil and
gas well, must either be routed to a gas gathering line or controlled from the date of
first production by air pollution control equipment that achieves an average
hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a
design destruction efficiency of at least 98% for hydrocarbons.
OPERATING a MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (OEM) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to the OEM plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. This source is not required to conduct initial testing, unless otherwise directed by the
Division or other state or federal requirement.
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part
A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as
follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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.
4 CDA E COLORADO
Ct Air Pollution Control Division
Page 4 of 9
• Whe ;ter th nge in thµ ow or opera; y facility, •cess, or
activ. or
• ver n _ contr quip =nt is ins'g '-d, orJeneveradffjyPe of
quipment •
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
18. 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.
19. 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.
20. 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.
21. 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.
22. 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.
23. 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
cult COLORADO
CO - Air Pollution Control Division
Page 5 of 9
„b
ision in44„'ng rr - cancell. ion ; the perms n notificat , annual
®- billing w erm te.
24. ' .lation e ter:ter:A of a ”, mit of the ps$°isions the Colorado A Pollution
-veh .n and C• t or a ions ff• •e result in
civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Christopher Kester
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to Longs Peak Resources, LLC
cDP" COLORADO
421.
COAir Pollution Control Division
X
. � ..E Page 6 of 9
"-•
Notes ti ?^ermit Hot at t - rthis perm-
e?. iss ce:
1) Th- -rmit hold s re.' ed gay fees f t e p -ssing ti for his permit 1,V-'n invoice
for -se fe l be i°,,< ed a ° the .;-' mit is is -d. Th ermit holder s .$ pay the
i in 30 da =ceip goice. he invoic- -moult 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.
Facility AIRS Uncontrolled Controlled
Equipment Point Pollutant CAS # Emissions Emissions
ID (lb/yr) (lb/yr)
Benzene 71432 1,198 60
Toluene 108883 1,884 94
SEPARATOR 006 Ethylbenzene 100414 543 27
Xylenes 1330207 2,196 110
n-Hexane 110543 17,540 879
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.
DP HE COLORADO
CO Air Pollution Control Division
Page 7 of 9
qs
5) Th fission le �; con is permit; re ..ed on th g emissio .,.ctors:
If
Poi 006: -44
� filled ,'�,��-.•: ���
CAS # Pollutant Emission Emission Source
Factors Factors
(lb/MMSCF) (lb/MMSCF)
CO 0.31 (lb/MMBtu) 0.31 (lb/MMBtu) AP-42
VOC 33808.167 1690.408
71432 Benzene 38.918 1.946 Site Specific
108883 Toluene 61.251 3.063 Emission Factors
100414 Ethylbenzene 17.531 0.877 based on Gas
1330207 Xylene 71.289 3.564 Sample Analysis
110543 n-Hexane 570.386 28.519
Note: The controlled emissions factors for this point are based on the combustor 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 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 Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC
PSD Synthetic Minor Source of:
VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations
can be found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart KKKK
NSPS Part 60, Appendix A - Appendix I
Appendixes
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
` CDPHE COLORADO
43,
CO er Air Pollution Control Division
E-, .,,_,•.� Page 8 of 9
.
T 63. 0-634t:.. @ 4 Subpart Z bpart { u,,
T 63. 0-Ens Subpar : ubpart XX
4 CDPNE COLORADO
CO An Pollution Control Division
Page 9 of 9
CDPHE Reciprocating Internal Combustion
'* 7ra Engine APEN - Form APCD-201 ;
CO • Air Pollutant Emission Notice (APEN) and I a
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 reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.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: WE)5.$6,3 AIRS ID Number: /Z3 / FCC/ / cdz_
nk unle5, :,?EL') iD?rmi[ rn =,I IDl
Section 1 - Administrative Information
Company Name': Longs Peak Resources, LLC
Site Name: Oxnard East
Site Location
Site Location:
SESE Sec. 31, T12N R66W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
•
Northglenn, CO 80234 Permit Contact: David Clarkson
Phone Number: 303-997-5558
Portable Source
Home Base: E-Mail Addressz: dclarkson@vrtxep.com
1
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits,exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
381748
COLORADO
_ .,, �rCu- , cc.f--u — !! umbu rOn .,pE!3 - Re,ision 1 .2317
Permit Number: AIRS ID Number:
Section 2 - Requested Action
E NEW permit OR newly-reported emission source (check one below)
❑ STATIONARY source ❑ PORTABLE source
✓❑ Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested, the General Permit registration fee of$1,500.00 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 ❑ Add point to existing permit
E Change permit limit E Transfer of ownership' E Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit-exempt/grandfathered source
E Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info a Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form(Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No. GEN1
General description of equipment and purpose: Natural gas fired generator
For existing sources, operation began on: 3/2/2018
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http://www.colorado.gov/cdphe/attainment) El Yes No
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25
COLORADO
n_�� 1J i_ �n ,,.,.,n ��' 2 °C,T7E„w.=
Permit Number: AIRS ID Number:
ilk ICI
Section 4 - Engine Information
Engine 0 Primary and/or Peaking ❑ Emergency Back-up ❑ Compression
Function: ❑ Pump ❑ Water Pump ❑ Other:
What is the maximum number of hours this engine will be used for emergency hours/year
back-up power? 0
Engine Make: Doosan/PSI Engine Model: D0146TIC Serial Number': EEZOG-401354
What is the maximum designed horsepower rating? 362 hp What is the engine displacement? 1.825 l/cyl
What is the maximum manufacturer's site-rating? 362 ' hp 225 kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 9000 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2-Stroke 4-Stroke Combustion: ❑ Lean Burn 0 Rich Burn
Ignition Source: 0 Spark ❑ Compression Aspiration: ❑ Natural 0 Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑ Yes ❑ No
If yes, what type of AFRC is in use? ❑ Oz Sensor (mV) ❑NOx Sensor (ppm) ❑ Other:
Is this engine equipped with a Low-NOx design? ❑ Yes 0 No
Engine Dates:
What is the manufactured date of this engine? 1/27/2015
What date was this engine ordered? NA
What is the date this engine was first located to Colorado? NA
What is the date this engine was first placed in service/operation? NA
What is the date this engine commenced construction? NA
What is the date this engine was last reconstructed or modified? NA
Is this APEN reporting an AOS replacement engine? ❑ Yes 0 No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
A® COLORADO
,44
Permit Number: AIRS ID Number:
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.45863/-104.81278
Operator Discharge Height Temp. Flow Rate Velocity
Stack ID No. Above Ground Level (.F) (ACFM) (ft/sec)
(Feet)
GEN1 7 1350 1487 71
Indicate the direction of the Stack outlet: (check one)
Q Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑ Other (describe):
Indicate the stack opening and size: (check one)
E Circular Interior stack diameter (inches): 8
❑ Square/Rectangle Interior stack diameter (inches): Interior stack depth (inches):
❑ Other(describe):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limit7
(SCF/hour) (MMSCF/year) (MMSCF/year)
2125 ' 18.62
From what year is the actual annual amount? 201 8
Indicate the type of fuel used8:
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑✓ Field Natural Gas Heating value: 1533 - BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other(describe): Heating Value (give units):
Requested values will become permit limitations. Requested limit(s)should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the "Other"field.
o
= -i �� COLORADO
�i _ � 4 I
If
Permit Number: AIRS ID Number:
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
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):
Overall Requested Control
Pollutant Primary Control Equipment Description Efficiency
(%reduction in emissions)
TSP (PM)
PM10
PM2.5
SOX
NOX NSCR 88.92
VOC
CO NSCR 86.83
Other:
Use the following tables to report criteria and non-criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data? 2018
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions9 Requested Annual Permit
Pollutant Emission Limit(s)7
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions Emissions Emissions
Mfg. etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year)
TSP (PM) 1.94E-2 Ib/MMBtu AP-42 0.28 0.28
PM10 1.94E-2 Ib/MMBtu AP-42 0.28 0.28
PM2.5 1.94E-2 Ib/MMBtu AP-42 0.28 0.28
SOX 5.88E-4 Ib/MMBtu AP-42 0.008 0.008
NOX 2.21 / Ib/MMBtu AP-42 31.54 i 3.50
VOC 0.70 - g/hp-hr Manufacturer 2.45 i 2.45
CO 3.72 - Ib/MMBtu AP-42 53.08 .- 6.99
Does the emissions source have any uncontrolled actual emissions of non-criteria ❑ Yes ❑ No
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, please use the following table to report the non-criteria pollutant (HAP) emissions from source:
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions9
Chemical Name Abstract Source Uncontrolled
Service(CAS) Uncontrolled Units (AP-42, Emissions Controlled Emissions
Number Basis Mfg. etc) (Pounds/year) (Pounds/year)
Formaldehyde 50000 2.05E-2 - Ib/MMBtu AP-42 585.1 - 585.1
Acetaldehyde 75070
Acrolein 107028
• Benzene 71432
Other:
Requested values will become permit limitations. Requested limit(s) should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
COLORADO
- _ - 5 ��
- '. - I � �iryi tv Fsrremmn
Permit Number: AIRS ID Number:
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 GP02, I further certify that this source is and will
be operated in full compliance with each condition of general permit GP02.
itirlAAde s./ !�
Signature of Legally Authorized Person (not a vendor or consultant) Date
David Clarkson COO
Name (please print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
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$1,500, if applicable to:
Colorado Department of Public Health and Small Business Assistance Program
Environment (303) 692-3175 or (303) 692-3148
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver, CO 80246-1530
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
COLORADO
CDPHE Reciprocating Internal Combustion
Engine APEN - Form APCD-201
•
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 reciprocating internal combustion engines (RICE). If your engine is a diesel compression
ignition engine or your emission unit does not fall into the RICE category, there may be a more specific APEN for
your source (e.g. diesel compression ignition engine, mining operations, asphalt plant, crusher, screen, etc.). In
addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your
reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.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: /g►VE0 ti• AIRS ID Number: 1z3 /qpctit/ 063
Di
Section 1 - Administrative Information
Company Name': Longs Peak Resources, LLC
Site Name: Oxnard East
Site Location
Site Location: SESE Sec. 31, T12N, R66W County: Weld
NAICS or SIC Code:• 1311
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
Northglenn, CO 80234 Permit Contact: David Clarkson
Phone Number: 303-997-5558
Portable Source E-Mail AddressZ:
Home Base: dclarkson@vrtxep.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.
3817 4 9
��o COLOSRADO
rr� CD-2U1 ��ri -atin= �mbL, -,i_rn ;ine �.P�ia - ion I _ 7' 1 H°,a `�,o"m°;
Permit Number: AIRS ID Number:
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source (check one below)
❑ STATIONARY source ❑ PORTABLE source
❑✓ Request coverage under a Construction Permit
❑ Request coverage under General Permit GP023 (Natural Gas Only)
If General Permit coverage is requested,the General Permit registration fee of$1,500.00 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 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit-exempt/grandfathered source
❑ Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info a Notes:
3 Only one engine may be reported per APEN for GP02 coverage. Coverage under GP02 is voluntary.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
5 This does not apply to General Permit GP02, as it does not contain a provision for AOS permanent replacements.
Section 3 - General Information
Does this engine have a Company Equipment Identification No. (e.g. ENG-1, Engine 3, etc)? Yes
If yes, provide the Company Equipment Identification No. GEN2
General description of equipment and purpose: Natural gas fired generator
For existing sources, operation began on: 3/3/2018
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
(http://www.colorado.Rov/cdphe/attainment) ❑ Yes ❑ No
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Seasonal use percentage: Dec-Feb: 25 Mar-May: 25 June-Aug: 25 Sept-Nov: 25
COLORADO
arc
Permit Number: AIRS ID Number:
Section 4 - Engine Information
Engine 0 Primary and/or Peaking ❑ Emergency Back-up ❑ Compression
Function: ❑ Pump ❑ Water Pump ❑ Other:
What is the maximum number of hours this engine will be used for emergency hours/year
back-up power? 0
Engine Make: Doosan/PSI Engine Model: D081 NA Serial Number': EEPOF-301291
What is the maximum designed horsepower rating? 106 hp What is the engine displacement? 1.35 l/cyl
What is the maximum manufacturer's site-rating? 106 hp 70 kW
What is the engine Brake Specific Fuel Consumption at 100% Load? 12928 BTU/hp-hr
Engine Features:
Cycle Type: ❑ 2-Stroke ❑✓ 4-Stroke Combustion: ❑ Lean Burn E Rich Burn
Ignition Source: ❑✓ Spark ❑ Compression Aspiration: ❑✓ Natural ❑ Turbocharged
Is this engine equipped with an Air/Fuel ratio controller (AFRC)? ❑ Yes ❑ No
If yes, what type of AFRC is in use? ❑ O2 Sensor (mV) ❑NOX Sensor (ppm) ❑ Other:
Is this engine equipped with a Low-NOX design? ❑ Yes E No
Engine Dates:
What is the manufactured date of this engine? 5/13/2013
What date was this engine ordered? NA
What is the date this engine was first located to Colorado? NA
What is the date this engine was first placed in service/operation? NA
What is the date this engine commenced construction? NA
What is the date this engine was last reconstructed or modified? NA
Is this APEN reporting an AOS replacement engine? ❑ Yes IO No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make: Engine Model: Serial Number:
6 The serial number must be submitted if coverage under GP02 is requested.
COLORADO
r it-?x'17 �.r-i � ��'" _ IIl - _ S10�� c��� %
1,4
Permit Number: AIRS ID Number: / /
_ 25 !�
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.45863/-104.81278
Operator Discharge Height
P Temp. Flow Rate Velocity
Above Ground Level
Stack ID No. ('F) (ACFM) (ft/sec)
(Feet)
GEN1 7 1350 606 51
Indicate the direction of the Stack outlet: (check one)
❑✓ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑ Other(describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): 6
❑ Square/Rectangle Interior stack diameter (inches): Interior stack depth (inches):
❑ Other(describe):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate @ 100%Load Actual Annual Fuel Use Requested Annual Permit Limit'
(SCF/hour) (MMSCF/year) (MMSCF/year)
894 - 7.83
From what year is the actual annual amount? 2018
Indicate the type of fuel used':
❑ Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf)
❑✓ Field Natural Gas Heating value: 1533 BTU/scf
❑ Propane (assumed fuel heating value of 2,300 BTU/scf)
❑ Landfill Gas Heating Value: BTU/scf
❑ Other(describe): Heating Value (give units):
Requested values will become permit limitations. Requested limit(s)should consider future process growth.
8 If fuel heating value is different than the listed assumed value, provide this information in the"Other"field.
COLORA
�n _.,--- -_i - l 4m, D
��O
Permit Number: AIRS ID Number:•
Section 7 - Emissions Inventory Information
Attach all emission calculations and emission factor documentation to this APEN form. The APCD website has a
Natural Gas Fired Engines Calculator available to assist with emission calculations.
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):
Overall Requested Control
Pollutant Primary Control Equipment Description Efficiency
(%reduction in emissions)
TSP (PM)
PM t0
PM2.5
Sox
NOX NSCR 92.28
VOC
CO NSCR 90.83
Other:
Use the following tables to report criteria and non-criteria pollutant emissions from source:
(Use the data reported in Section 6 to calculate these emissions.)
From what year is the following reported actual annual emissions data? 2018
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions' Requested Annual Permit
Emission Limits)
7
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions Emissions Emissions
Mfg. etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year)
TSP (PM) 1.94E-2 lb/MMBtu AP-42 0-12 0.12
PM10 1.94E-2 Ib/MMBtu AP-42 0.12 0.12
PM2.5 1.94E-2 Ib/MMBtu AP-42 0.12 0.12
SOX 5.88E-4 lb/MMBlu AP-42 0.0035 0.0035
NOX 2.21 Ib/MMBtu AP-42 13.27- 1.02
VOC 0.70 g/hp-hr Manufacturer 0.72/ 0.72
CO 3.72 lb/MMBtu AP-42 22.33 2.05/
Does the emissions source have any uncontrolled actual emissions of non-criteria ❑ Yes ❑✓ No
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, please use the following table to report the non-criteria pollutant (HAP) emissions from source:
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions'
Chemical Name Abstract Source Uncontrolled
Service (CAS) Uncontrolled Controlled Emissions
Basis Units (AP 42, Emissions (Pounds/year)
Number Mfg. etc) (Pounds/year)
Formaldehyde 50000
Acetaldehyde 75070
Acrolein 107028
Benzene 71432
Other:
7 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
9 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
„ COLORADO
5 I °a
Permit Number: AIRS ID Number: / / •
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 GP02, I further certify that this source is and will
be operated in full compliance with each condition of general permit GPO2.
hae25"/41* /8
Signature of Legally Authorized Person (not a vendor or consultant) Date
David Clarkson COO
Name (please print) Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
❑ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
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$1,500, if applicable to:
Colorado Department of Public Health and Small Business Assistance Program
Environment (303) 692-3175 or (303) 692-3148
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver, CO 80246-1530
Make check payable to: https://www.colorado.gov/cdphe/apcd
• Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
COLORADO
Receive-A
CDPHE Crude Oil Storage Tank(s) APEN -
4D4Form APCD-210
CO Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re-submittal.
This APEN is to be used for tanks that store crude oil associated with oil and gas industry operations. If your emission
source does not fall into this category, there may be a more specific APEN available for your source (e.g. condensate
storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form
APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN
forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.gov/pacific/cdphe/air-permits.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to'expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: W °SC , AIRS ID Number: 1Z I S
[Leave blank unless APCD has already assigned a permit r:and AIRS ID]
Section 1 - Administrative Information
Company Name': Longs Peak Resources, LLC
Site Name: Oxnard East
Site Location
Site Location: SESE Sec. 31, T12N, R66W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
Northglenn, CO 80234 Permit Contact: David Clarkson
Phone Number: 303-997-5558
E-Mail Address2: dclarkson@vrtxep.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided.
COLORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 02/2017 1 VT' �ew, ��
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit g and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
✓❑ Request coverage under traditional construction permit
❑ Request coverage under General Permit GP08
If General Permit coverage is requested, the General Permit registration fee of$250 must be
submitted along with the APEN filing fee.
-OR-
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 -
11 APEN submittal for permit exempt/grandfathered source
Additional Info Et Notes: Updated with site specific emission factors
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: 4-400 bbl Crude Oil Tanks
For existing sources, operation began on: 2/16/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: Exploration a Production (EaP)site ❑ Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? ❑ Yes 0 No
Are Flash Emissions anticipated from these storage tanks? 0 Yes ❑ No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑ Yes ❑✓ No
805 series rules? If so, submit Form APCD-105.
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual 0 Yes ❑ No
emissions≥ 6 ton/yr (per storage tank)?
COLORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 02/2017 ' 2 �Vlie.. Li,„, :,,,
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit 4 and AIRS ID)
Section 4 - Storage Tank(s) Information
ActuaLAnnualAmount Requested Annual Permit Limit4
(bbl/year) (bb(/year)
Crude Oil Throughput: 69905
From what year is the actual annual amount?
Average API gravity of sales oil: 37 degrees RVP of sales oil:
Tank design: Fixed roof ❑ Internal floating roof ❑ External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TANKS 4 1600 2/18 2/18
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only)
API Number Name of Well I Newly Reported Well
05 - 123- 456 Oxnard East#3130-12CH ✓❑
❑
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The E&P Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.45863/-104.81278
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level (feet) (°F) (ACFM) (ft/sec)
Combustor 35 1000
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑Other (describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter(inches): 96
❑Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑Other (describe):
ALORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 02/2017 3 mV C C.00 Y G�.wniernt
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit 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 Size: Make/Model: •
❑ Recovery
Unit (VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Pollutants Controlled: VOCs, HAPs
Rating: 1000 MSCfd MMBtu/hr
Type: Enclosed Make/Model:Crimson Energy/CE 1000
❑ Combustion Requested Control Efficiency: 95 90
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: NA Waste Gas Heat Content: 2575 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.02 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested: %
Section 7 -Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? —40 psig
Describe the separation process between the well and the storage tanks: gas and liquids from the
well are routed to a 2 phase vertical separator, gas is sent to combustor, liquids are sent to
heater treater, water sent to water tanks and oil sent to oil tanks
AV'
COLORADO
Form APCD-210- Crude Oil Storage Tank(s) APEN - Revision 02/2017 4 I m� °`°"""'"""'""H6LLN!Fnr..�...n:
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit h 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
(or combined) control efficiency (%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction in emissions)
VOC Combustor 95
NOx
CO
HAPs Combustor 95
Other:
From what year is the following reported actual annual emissions data? 2018
Criteria Pollutant Emissions Inventory
Emission Factor6 Actual Annual Emissions Requested AnnualPermit
Emission Limit(s)4
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions Emissions • Emissions
•
Mfg.etc) (Tons/year) (Tons/year) .' (Tons/year) (Tons/year)
VOC 7.49 — lb/bbl State Default 261.79 i 13.09 "'
NOx 0.068 Ib/MMBtu AP-42 0.49 " 0.49 i
CO 0.31 — Ib/MMBtu AP-42 2.24 — 2.24 -
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor6 Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled �
Units (AP-42, Emissions Emissions
- Number Basis Mfg. etc) Pounds/ ear g ( y ) (Pounds/year)
Benzene 71432
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543 0.065 lb/bbl E&P Tanks 4543.8-' 227.2 --
2,2,4-
540841
Trimethylpentane
4 Requested values will become permit limitations. Requested limit(s)should consider future growth.
6 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
'Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
COLORADO
Form APCD-210 - Crude Oil Storage Tank(s) APEN - Revision 02/2017 5 I AV °°pi7,;71 °'"""
Hr�t�b b Gwenment
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under General Permit GP08, I further certify that this source is and will
be operated in full compliance with each condition of the applicable General Permit.
&(,..044,4,e_ /o -tZ' /r
Signature of Legally Authorized Person (not a vendor or consultant) Date
David Clarkson COO
Name (print) Title
Check the appropriate box to request a copy of the:
0 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 Small Business Assistance Program
Environment (303) 692-3175 or(303) 692-3148
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver,CO 80246-1530
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303)692-3150
COLORADO
Form APCD-210- Crude Oil Storage Tank(s)APEN - Revision 02/2017 6 I ,AV
eoCt letted 1ojir/I4
CDPHE Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Co • 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.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: I g WCO SG7 AIRS ID Number: I Z hC9 /DD(p
[Leave blank unless APCD has already assigned a permit C and AIRS ID]
Company equipment Identification: SEPARATOR
[Provide Facility Equipment ID to identify how this equipment is referenced within your organization]
Section 1 - Administrative Information
Company Name': Longs Peak Resources, LLC
Site Name: Oxnard East
Site Location
Site Location: SESE Sec. 31, T12N, R66W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
Northglenn, CO 80234 Permit Contact: David Clarkson
Phone Number: 303-997-5558
E-Mail Address' dclarkson@vrtxep.com
'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.
COLORADO
Form APCD-205 - Natural Gas Venting APEN - Rev 03/2017 1 ��1====,
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit H 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 ownership' ❑ Other (describe below)
-OR-
❑ APEN submittal for update only (Please note 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: updated for site specific emission factors
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: Flaring of separator gas for wildcat well,
no gathering pipeline in place
For existing sources, operation began on: 02 / 16 / 2018
For new or reconstructed sources, the projected
start-up date is:
❑ 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 days/week weeks/year
Will this equipment be operated in any NAAQS nonattainment ❑ Yes ❑✓ No
area
Is this equipment located at a stationary source that is ❑ Yes ❑✓ No
considered a Major Source of (HAP) Emissions
COLORADO
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 2 �' �°un:�
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: Gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes ❑ No
Maximum Vent 11700 SCF/hr Vent Gas 1492 BTU/SCF
Natural Gas Venting Rate: Heating Value:
Process Parameters4: Requested: 30.7 MMSCF/year Actual: MMSCF/year
-OR-
Liquid Throughput
4 Requested: Bbl/yr Actual: Bbl/yr
Process Parameters :
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Molecular Weight:
VOC (mole%) VOC (Weight%) 43.39
Benzene (mole%) Benzene (Weight%) 0.0535
Toluene (mole%) Toluene (Weight%) 0.0842
Process Properties:
Ethylbenzene (mole%) Ethylbenzene (Weight%) 0.0243
Xylene (mole%) Xylene (Weight%) 0.0982
n-Hexane (mole%) n-Hexane (Weight%) 0.7854
2,2,4-Trimethylpentane 2,2,4-Trimethyipentane 0.0008
(mole%) (Weight%)
Additional Required Information:
❑✓ Attach a representative gas analysis (including BTEX Et n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis (including BTEX Et n-Hexane, temperature, and
pressure)
COLORADO
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 3 I �� :�..°"ww
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.45863/-104.81278
�..� 4 ;� `� �s
• cs• Tem low Rate e[ocrt « e
7�5
Op;sec)
COMBUSTOR 35 1000 variable variable
Indicate the direction of the stack outlet: (check one)
✓❑ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal ❑ Other (describe):
Indicate the stack opening and size: (check one)
❑✓ Circular Interior stack diameter (inches): 96
❑ Other (describe):
Section 6 - Control Device Information
Pollutants Controlled:
Size: Make/Model:
❑ VRU:
Requested Control Efficiency %
VRU Downtime or Bypassed %
Pollutants Controlled: VOC, HAPs, H2S
Rating: 1000 mscfd MMBtu/hr
Type: Enclosed Make/Model: Crimson Energy, CE 1000
❑ Combustion Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency 98 %
Minimum Temperature: NA Waste Gas Heat Content 1492 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating 0.02 MMBtu/hr
Pollutants Controlled:
El Other: Description:
Control Efficiency
Requested
COLORADO
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 4 I °. ,
Permit Number: AIRS ID Number:
[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):
Overall Requested Control
Pollutant Control Equipment Description Efficiency
(%reduction in emissions)
PM
SOX
NO,
VOC Combustor 95
CO
HAPs Combustor 95
Other:
From what year is the following reported actual annual emissions data? 2018
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.)
Emission : xRequested Annual Permit
Uncontrolled Emission Factor 41 Actual Annual Emissions ' Emission Lima{sjs�
} ' ,� '.
Pollutant Emission Factor `Source.. �- �
Factor Units (Ap-42, Uncontrolled Controlled6 Uncontrolled Controlled
Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year)
PM
SOX
NO, 0.068 Ib/MMBtu AP-42 1.56 - 1.56—
VOC 23.07 Ib/MMBtu Mass Balance 518.88' 25.94
CO 0.31 Ib/MMBtu AP-42 7.11 - 7.11 -
Benzene 57.50 lb/mmscf Mass Balance 0.60 - 0.03
Toluene 158.27 lb/mmscf Mass Balance 0.94 - 0.05
Ethylbenzene 11.49 lb/mmscf Mass Balance 0.27 - 0.01
Xylenes 121.58 lb/mmscf Mass Balance 1.10 ' 0.05
n-Hexane 862.94 lb/mmscf Mass Balance 8.78 - 0.44
2,2,4-
Trimethylpentane
Other:
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
(COLORADO
Form APCD-205 -Natural Gas Venting APEN - Rev 03/2017 5 �V'° �`"�w�""
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit k 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. 6/61,7/-34,L.4etoe:,Signature of Legally Authorized Person (not a vendor or consultant) Date
David Clarkson COO
Name (please print) Title
Check the appropriate box to request a copy of the:
�✓ Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to: For more information or assistance call:
Colorado Department of Public Health and
Environment Small Business Assistance Program
Air Pollution Control Division (303)692-3175 or (303)692-3148
APCD-SS-B1
4300 Cherry Creek Drive South Or visit the APCD website at:
Denver,CO 80246-1530
https://www.colorado.gov/cdphe/apcd
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303)692-3150
6
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Form APCD-2O5 -Natural Gas Venting APEN - Rev 03/2017 n"
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