HomeMy WebLinkAbout20173989.tiffCOLORADO
Department of Public
Health €t Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
November 16, 2017
Dear Sir or Madam:
RECEIVED
NOV 202017
WELD COUNTY
COMMISSIONERS
On November 30, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for
Longs Peak Resources, LLC - Pismo 35-2-2-2CH. A copy of this public notice and the public comment
packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Ft Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
(� John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
1 C.)COItC �Vie,(,L) CG:PLCmn�f-rP), HLC- fl,
lO'1�E-i �[� P /OCE-Raa �7H/Sf?icK
2017-3989
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: Longs Peak Resources, LLC - Pismo 35-2-2-2CH
- Weld County
Notice Period Begins: November 30, 2017
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: Pismo 35-2-2-2CH
Welt production facility
NWNE Section 35 T12N R66W
Weld County
The proposed project or activity is as follows: Well production facility in the ozone attainment area in Weld
County. Permitted points are a generator engine, crude oil storage, separator venting, produced water
storage. Also included in this project is a permit -exempt crude oil loadout point.
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 Permits 17WE0737, 17WE0739,
17WE0740 and 17WE1074 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:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLORADO
1 I M:
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑'arbon Monoxide (CO)
Andy Gruel
366196:=- » i
7114/2Q17';revi
1112j2m 7;;,,
wised Oct 2017
..... ...........
Peak Resources;
123;.
9545
Pismo:35,2-2-2CI ..
NWNE quadrant of Section 35, Township 12N, Range 66W, in Weld County, Colorado
Weld
Quadrant
Section
Township
Range
NWNE
Section 02 - Emissions Units In Permit Application
articulate Matter (PM) ❑lzone (NOx & VCC)
AIRs Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Natt�Gas
GE M1k1.;
5
17WEti 37
EPA
}E�,q
i ial
002. '
:'
ocarbon Liquid Loadin
LOAD=
4,
1 E 73XP1
XP
1p 0
t
gafJYr .
003
> Otl �a
TANKS
1 1 tf739
CP1
€1043
orVen
SEPARATOR
PgO0_WT'it
_.x< ;. i3 qr"
�f YYE���!FFI 3
��:,f.F'�'-.
74
e
..�.: !�\... •
': .. is � �mti 0� �..
� ...
a�j�:7\��
,R
`�.
Section 03 - Description of Project
ttiai application received.7/14/17 Revised"APEN5.for all ponts
Oct 2017 revisions.. TES#
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
r�.
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
0000 ❑ ❑
❑ ❑ O o O ❑ ❑ o
❑ ❑
ate;:
Is this stationary source a major source?
If yes, explain what programs and which pollutants here: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) O O O O O O
Title V Operating Permits (OP) O O O O O O O O
Non -Attainment New Source Review (NANSR) O ❑
Summary of Preliminary Analysis - NG RICE
Company Name Longs Peak Resources, LLC
Facility Name Pismo 35-2-2-2CH
Facility Location NWNE Section 35 T12N R66W
Facility Equipment ID GEN1
Permit No.
AIRS
Review Date
Permit Engineer
17WE0737
12319F491001
11/06/2017
Andy Gruel
Requested Action New permit/newly reported emission
Issuance No. 1
Emission Point Description
One (1) PSI, Model 11.1L, Serial Number To Be Determined, natural gas -fired, turbo -charged, 4SRB reciprocating internal
combustion engine, site rated at 302 horsepower. This engine shall be equipped with a non -selective catalytic reduction
(NSCR) system and air -fuel ratio control. This emission unit powers a generator.
Natural Gas Consumption
Requested (mmscf/yr)
18.53
Requested (mmscf/m)
1.57
Fuel Heat Value (btu/scf)
1476.4
BSCF (Btu/hp-hr)
10339.69
Emission Factor Sources
Hours of Operation
PTE Calculated at (hpy)
Permit limits calculated at (hpy)
8760
8760
Uncontrolled
Controlled
NOx
AP -42; Table 3.2-3 (7/2000); Natural Gas
Applicant
VOC
Manufacturer's spec
No Control
CO
AP -42; Table 3.2-3 (7/2000); Natural Gas
Applicant
Formaldehyde
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
SOX
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
TSP
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
PM10
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
PM2.5
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
Other Pollutants
AP -42; Table 3.2-3 (7/2000); Natural Gas
No Control
Point Summary of Criteria Emissions (tpy)
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
NOx
30.23
2.91
30.23
90.4%
VOC
2.04
2.04
2.04
0.0%
CO
50.88
5.83
50.88
88.5%
SOx
0.0
0.0
0.0
0.0%
TSP
0.3
0.3
0.3
0.0%
PM10
0.3
0.3
0.3
0.0%
PM2.5
0.3
0.3
0.3
0.0%
Total HAPs*
0.0
0.0
0.4
0.0%
*Uncontrolled requested and controlled requested totals include HAPs only if the uncontrolled actual values are above de
minimus thresholds. PTE includes all HAPs calculated, even those below de minimus.
Point Summary of Hazardous Air Pollutants (lb/yr
HAP Name
Uncontrolled
Requested
Controlled
Requested
PTE
Proposed Control
Efficiency
Formaldehyde
561
561
561
0.0%
Methanol
*
*
84
0.0%
Acetaldehyde
*
*
76
0.0%
Acrolein
*
*
72
0.0%
Benzene
*
*
43
0.0%
1,3 -Butadiene
*
*
18
0.0%
Toluene
*
*
15
0.0%
*Uncontrolled requested and controlled requested values are shown only for pollutants where REQUESTED
UNCONTROLLED is greater than de minimus
Permitting Requirements
Ambient Air Impacts
Source is not required to model based on Division Guidelines
Public Comment
Public Comment Required
MACT 7777
New/Recon 4SRB less than or equal to 500 HP located at a(n) Area Source
Reg 7 XVII.E
Standards (g/hp-hr)
NOx: 1.0 CO: 2.0 VOC: 0.7
Reg 7 XVI.B (Ozone NAA
requirements) applies?
No
MACT 7777 (area source)
Is this engine subject to MACT 7777 area
Yes
source requirements?
NSPS JJJJ
Is this engine subject to NSPS JJJJ?
Yes
Note: JJJJ requirements are not currently included as permit conditions because the reg has not
been adopted into Reg 6.
Comments/Notes
Applicant cid not provide dates for ordered/relocated/reconstruction, so I assumed the reported date of 5/16/17 in order to
make applicability determinations for NSPS JJJJ and MACT 7777.
COLORADO DEPARTMENT OF PUBLIC HEALTH ENVIRONMENT
AIR POLUTION CONTROL DIVISION
INVENTORY
AIRS (County/Plant) 123/9F49/001
Permit No. 17WE0737
Date 11/6/2017
Engine Type 4SRB
Point #
Seg *
SCC
Pollutant or CAS
Fug
Dust
Uncontrolled
Emission Factor
Emisison Factor Source
Controlled
Actual
Emissions
(tpy)*
Controlled
Requested
Emissions
(tpy)*
PTE (tpy)*
Ctrl.
Eff%
NCRP =
reportable
?
001
2-02-002-53
NOx
n
3262.84 lb/MMscf
Applicant
2.9
30.2
90%
CO
n
5492.21 Ib/MMscf
Applicant
5.8
50.9
89%
VOC
n
220.358 lb/MMscf
Manufacturer's spec
2.0
2.0
0%
50000
Formaldehyde
n
30.2662 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
561
561
0%
Yes
67561
Methanol
n
4.51778 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
84
84
0%
No
75070
Acetaldehyde
n
4.11916 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
76
76
0%
No
107028
Acrolein
n
3.88293 lb/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
72
72
0%
No
71432
Benzene
n
2.33271 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
43
43
0%
No
106990
1,3 -Butadiene
n
0.97885 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
18
18
0%
No
108883
Toluene
n
0.82383 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
15
15
0%
No
1330207
Xylene
n
0.2879 lb/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
5
5
0%
No
0
PAH
n
0.20817 Ib/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
4
4
0%
No
91203
Naphthalene
n
0.14336 lb/MMscf
AP -42; Table 3.2-3 (7/2000); Natural Gas
3
3
0%
No'
NOTES
*Emissions of criteria are reported in tons/yr; emissions of NCRPs are in lb/yr.
Engine BSCF: 10339.6887417 Btu/hp-hr
Engine HP: 302
Fuel Heat Value: 1476.4 btu/scf
Controlled emissions shown above are calculated using the control efficiencies/factors specified, at the permitted fuel use rate (calculated at 8760 hpy)
PTE shown above is calculated based on the uncontrolled emission factors and the maximum potential fuel use rate (calculated at 8760 hpy)
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Longs Peak Resources, LLC
123
9F49
Pismo 35-2-2-2CH
History File Edit Date
Ozone Status
1112/2017
Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
'
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0,0
0.0
New Facility - No Previous Total
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
30.2
2.0
50.9
0.4
2.9
2.0
5.8
0.4
new point
002
17WE0738.XP
Loadout crude oil to tank trucks
4.3
0.1
4.3
0.1
XP due to less than 10,000 gelid crude oil
003
17WE0739
Crude oil storage (1600 bbl)
0.7
453.6
3.2
17.7
0.7
22.7
3.2
0.9
SSEFs accepted
004
17WE0740
Separator venting
4.0
1,267.2
18.3
48.1
4.0
63.4
18.3
2.4
SSEFs accepted
005
'17WE1074
Produced water storage (800 bbl)
29.4
3.2
1.5
0.2
State EFs
APEN-Exempt I Insignificants
XA
Heater -Treater
0.2
0.1
0.0
0.2
0.1
0.0
from Aug 2017 Form 102
XA
Fugitives
0.1
0.0
0.1
0.0
from Aug 2017 Form 102
XA
FLR Tank
0.7
0.0
0/
0.0
from Aug 2017 Form 102; separate tank battery is
XA due to emissions
XA
Loadout from FLR Tank
0.1
0.0
0.1
0.0
from Aug 2017 Form 102; loadout activity is XA
due to emissions
XA
"GEN2": PSI 11.1L
1.7
0.1
2.9
0.0
0.2
0.1
0.3
0.0
from Aug 2017 Form 102; used only during startup
of pump
FACILITY TOTAL
0.0
0.0
0.0
0.0
36.9
1,757.4
0.1
75.4
69.5
0.0
D.0
0.0
0.0
8.0
94.8
0.1
27.8
3.9
VOC: Syn Minor (PSD and OP)
NOx: Minor (PSD and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor n -hex and Total
HH: Syn Minor + affected Area
ZZZZ: Syn Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
35.0
1,752.2
0.0
72.4
69.4
0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
3.9
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
Pubcom required based on new syn minor limits
Note 1
Total VOC Facility
(A) Change in Total Permitted VOC
Emissions (point and fugitive
emiss ons (point and fugitive)
94.9
Facility is eligible for GP02 because ' 90 tpy
Project emissions less than 25/50 tpy
89.6
Initial application reed July 2017; wholesale revisions rec'd Aug 31 2017; minor re -revision received Oct 2017.
Note 2
Page 1 of 2
Printed 11/7/2017
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Longs Peak Resources, LLC
County AIRS ID 123
Plant AIRS ID 9F49
Facility Name Pismo 35-2-2-2CH
Emissions - uncontrolled (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
4948
1509
70
447
27114
1244
17.7
004
17WE0740
Separator venting
6257
14625
3725
7225
60998
3379
48.1
005
17WE1074
Produced water storage (800 bbl)
1569
4930
3.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTAL,tpy)
0.3
0.0
0.0
6.4
8.1
1.9
3.8
46.6
0.0
2.3
0.0
0.0
69.5
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
!Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
247
75
3
22
1356
62
0.9
004
17WE0740
Separator venting
313
731
186
361
3050
169
2.4
005
17WE1074
Produced water storage (800 bbl)
78
246
0.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadoutfrom FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTALJtpy)
0.3
0.0
0.0
0.3
0.4
0.1
0.2
2.4
0.0
0.1
0.0
0.0
3.9
1239F49.xlsx
11/7/2017
Colorado Air Permitting Project
Project Details
Review Engineer:
Package,#:
Received Date:
Review Start Date:
Section 01- Facility Information
Andy Gruel
36619&
7/14/2017 . revised As
11/2/201
evised Oct 2017
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? ❑ arbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
LongsPeak:Resources, a
Weld
Quadrant
Section
Township
Range
NWNE
NWNE quadrant of Section 35, Township 12N, Range 66W, in Weld County, Colorado
articulate Matter (PM)
DDzone (NOx & VOC)
AIRS Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
GEN1:
1J'WEf1737
CPI
.,./.,,, 77 73
E� 1g lIl133333 3 3
002 -
/
LOAD
07738 17WE .... �1?�
a ttderotf
OO3
01 5p4
t
TANKS
17WEO73}
7,6/
for en i
._,.x,...::SEPARATOR
?
EO74(?
;; CPi.....,.
_YY f,T
4��°e°'
f f � f,
• CPL
\\`�\ ,,'�
C@r
Section 03 - Description of Project
initial application recetved 7/1,
analysis iS based ttn the -Aug 20
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
d APEI'fsfor ail ports recd 8/31/17 once sites
evis ans This is a new E&P site in far nos
5 completed.: Additional i
ty and no sales gas line is availa
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
El ❑ ❑ O ❑ Cl
❑ ❑ ❑ O O O ❑ O
❑ O
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ ❑ ❑
❑ ❑ ❑ ❑ O O ❑ ❑
❑ ❑
Crude Oil Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
'Facility AIRs ID: 1�"=
County
Plant Poin
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03- Processing Rate Information for Emissions Estimates
Prinary Emissions - Storage Tank(s)
Actual Throughput =
Requested Permit Limit Throughput =
Barrels (bbl) per year
1,694'. Barrels (bbl) per year
Potential to Emit (PTE) Throughput = 82,664 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas muted to combustion device =
Section 04- Emissions Factors & Methodologies
WA this storage tank emit flash emissions?
17WE0739.cp1
Actual Crude Oil Throughput While Emissions Controls Operating =
from E&P TANKS run by applicant
0 MMBTU per year
20,647 MMBTU per year
20,647 MMBTU per year
Pollutant
Pollutant
Uncontrolled
Controlled
(16/661)
(Ib/bbl)
(Crude Oil
Throughput)
17
001'_...........
0.015 ..
(Crude Oil
Throughput)
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(waste heat
combusted)
(Ib/bbl)
(Crude Oil
Throughput)
0.0000
0.0000
0.0170
0.0774
Emission Factor Source
Emission Factor Source
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
VOC
453.6
- 0.0
0.0
453.59
22.68
PM10
0.0
0.0
0.0
0.0
0.0
PM2.5
0.0
0.0
0.0 -
0.0
0.0
NOx
0.7
0.0
0.0
0.70
0.70
CO
3.2
0.0
0.0
3.20
3.20
Potential to Emit
Actual Emissions -
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(lbs/year) (lbs/year)
(lbs/year) (lbs/year)
Benzene
4948
0
0
4948
247
Toluene
1509
0
0
1509
75
Ethylbenzene
70
0
0
70
3
Xylene
447
0
0
447
22
n -Hexane
27114
0
0
27114
1356
224 TMP
1244
0
0
1244
62
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A,B
Regulation 7, Section XVII.B, C.1, C.3
Regulation 7, Section XVII.C.2
Regulation 6, Part A, NSPS Subpart Kb
Regulation 6, Part A, NSPS Subpart 0000
Regulation 8, Part E, MACrSubpart HH
(See regulatory applicability worksheet for detailed analysis)
Source requires a permit
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Storage tank is subject to Regulation 7, Section XVII.C.2
Storage Tank is not subject to NSPS Kb
Storage Tank is not subject to NSPS 0000
Storage Tank is not subject to MAC! HH
Section 07 - Initial and Periodic Sampling and Testing Requirements
1 oft
K:\PA\2017\17 W E0739.CP1.xlsm
Crude Oil Storage Tank(s) Emissions Inventory
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 20 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample of crude oil drawn at the n ri
facility being permitted?
If no, the permit will contain an "Initial Compliance" besting requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device? -' y,✓�j/�y
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 -Technical Analysis Notes ___
,bppfcapt used E&PTANK5and a site•speciflc presserizedf'iquidsampleto caksbteflasfsjworkinglb
Section 09 - Inventory SCC Udine and Emissions Factors
AIRS Point # Process # SCC Code
003 01
Uncontrolled
Emissions
Pollutant Factor Control % Units
NO0 0.40 0 Ib/1,000 gallons crude oil throughput
VOC 261.2 95 lb/1,000 gallons crude oil throughput
CO 1.84 0 lb/1,000 gallons crude oil throughput
Benzene 1.42 95 lb/1,000 gallons crude oil throughput
Toluene 0.43 95 lb/1,000 gallons crude oil throughput
Ethylbenzene 0.02 95 lb/1,000 gallons crude oil throughput.
Xylene 0.13 95 Ib/1,000 gallons crude oil throughput
n -Hexane 7.81 95 lb/1,000 gallons crude oil throughput
224 TMP 0.36 95 lb/1,000 gallons crude oil throughput
2 of 2 K/iPA\2017\17WE0739.CP1.xlsm
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Longs Peak Resources, LLC
123
9F49
Pismo 35-2-2-2CH
History File Edit Date
Ozone Status
1112/2017
Attainment
EMISSIONS - Uncontrolled (tons per year
EMISSIONS With Controls (tons per year)
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
previous FACILITY TOTAL
0,0
O,Q
0.0
0,0
0,0
0.0
0.0
0.0 •
0,0
0.4
0,0
QQ
0,0
O,0
4.Q
0,0
Q,0
0,0
New Facility - No Previous TQtdi
Previous Permitted Facility
total
0.0
0.0'
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
30.2
2.0
50.9
0.4
2.9
2.0
5.8
0.4
new point
002
17WE0738.XP
Loadout crude oil to tank trucks
4.3
0.1
4.3
0.1
XP due to less than 10,000 gaud crude oil
003
17WE0739
Crude oil storage (1600 bbl)
0.7
453.6
3.2
17.7
0.7
22.7
3.2
0.9
SSEFs accepted
004
17WE0740
Separator venting
4.0
1,267.2
18.3
48.1
4.0
63.4
18.3
2.4
SSEFs accepted
005
17WE1074
Produced water storage (BOO bbl)
29.4
3.2
1.5
0.2
State EFs
APEN-Exempt / Insignificants
XA
Heater -Treater
0.2
0.1
0.0
0.2
0.1
0.0
from Aug 2017 Form 102
XA
Fugitives
-
0.1
0.0
0.1
0.0
from Aug 2017 Form 102
XA
FLR Tank --
0.7
0.0
0.7
0.0
from Aug 2017 Form 102; separate tank battery is
XA due to emissions
XA
Loadout from FLR Tank
0.1
0.0
0.1
0.0
from Aug 2017 Form 102; loadcut activity is XA
due to emissions
XA
"GEN2": PSI 11.1E
1.7
0.1
2.9
0.0
0.2
0.1
0.3
0.0
from Aug 2017 Form 102; used only during startup
of pump
FACILITY TOTAL
0.0
0.0
0.0
0.0
36.9
1,757.4
0.1
75.4
69.5
0.0
0.0
0.0
0.0
8.0
84.8
0.1
27.8
3.9
VOC: Syn Minor (PSD and OP)
NOx: Minor (PSD and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor n -hex and Total
NH: Syn Minor + affected Area
ZZZZ: Syn Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
35.0
1,752.2
0.0
72.4
69.4
0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
3.9
Excludes units exempt from permifs/APENs
(A) Change in Permitted Emissions
0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
Pubcom required based on new syn minor limits
Note 1
Total VOC Facility
(Li) Change in Total Permitted VOC
Emissions (point and fugitive
emissions (point and fugitive)
94.9
Facility is eligible for GP02 because < 90 tpy,
Prject emissions less than 25150 ipy
89.6
Initial application rec'd July 2017; wholesale revisions rec'd Aug 31 2017; minor re -revision received Oct 2017.
Note 2
Page I of 2
Printed 11/6/2017
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Longs Peak Resources, LLC
County AIRS ID 123
Plant AIRS ID 9F49
Facility Name Pismo 35-2-2-2CH
Emissions - uncontrolled (lbs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 IMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
4948
1509
70
447
27114
1244
17.7
004
17WE0740
Separator venting
6257
14625
3725
7225
60998
3379
48.1
005
17WE1074
Produced water storage (800 bbl)
1569
4930
3.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTAL jtpy)
0.3
0.0
0.0
6.4
8.1
1.9
3.8
46.6
0.0
2.3
0.0
0.0
69.5
'Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (Ibs per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
247
75
3
22
1356
62
0.9
004
17WE0740
Separator venting
313
731
186
361
3050
169
2.4
005
17WE1074
Produced water storage (800 bbly
78
246
0.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTAL (tpy)
0.3
0.0
0.0
0.3
0.4
0.1
0.2
2.4
0.0
0.1
0.0
0.0
3.9
2
1239F49.xlsx
11/6/2017
Colorado Air Permitting Project
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
ised Oct 2017
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? Larbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
AIRs Point # Emissions Source Type
Section 03 - Description of Project
Section 04 - Public Comment Requirements
diAPEN5)✓oS
VT
Weld
Quadrant
Section
Township
Range
NWNE quadrant of Section 35, Township 12N, Range 66W, in Weld County, Colorado
Particulate Matter (PM) axone (NOx & VOC)
Equipment Emissions
Name Control?
PARA°roR'
ICi = WTR
Permit # Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Is Public Comment Required?
If yes, why?
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor? = n -,'
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) O O O 0 ❑ O
Title V Operating Permits (OP) O O O O O O O O
Non -Attainment New Source Review (NANSR) O O
HAPs
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx CO VOC PM2.5 PM10 TSP
❑ ❑ ❑ ❑ O O
O O O O O O O O
❑ ❑
ate?
123-9F49-004 17WE0740 CP1 based on August 31 2017 APEN
Equipment Description
This source vents natural gas from:
Emissions from this source are:
one (1) secondary separator
routed to a flare
Natural gas venting from one (1) secondary separator. Emissions from this source are routed to a flare.
Calculations
Emission Calculation Method
EPA Emission Inventory Improvement Program Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3)
Ex=Q*MW*Xx/C
Ex = emissions of pollutant x
0 = Volumetric flow rate/volume of gas processed
MW = Molecular weight of gas = SG of gas * MW of air
Xx = mass fraction of x in gas
C = molar volume of ideal gas (379 scf/lb-mol) at 60F and 1 atm
Throughput (Q)
MW
80.1
26.92
MMscf/yr
Ib/Ib-mol
9143.835616
0.219452055
scf/hr
MMscf/d
mole
MW
!00!
Ibx/Ibmol
mass fraction
lb/hr
lb/yr
tpy
Helium
CO2
N2
methane
ethane
4.0026
0.000
1.309
0.388
0.000E+00
4.864E-02
1.443E-02
3.876E-01
1.041E-01
1.792E-01
2.742E-02
9.563E-02
2.926E-02
3.276E-02
2.321 E-03
0.0107213
1.913E-03
1.481E-02
3.208E-02
4.599E-03
0.0005941
0.0010998
0.0025708
0.0006547
0.0012699
8.253E-03
0.00
0.00
0.00
44.01
31.59
276723.63
138.36
28.013
16.041
30.063
44.092
58.118
58.118
72.114
72.114
9.37
82086.70
41.04
propane
isobutane
n -butane
isopentane
n -pentane
cyclopentane
n -Hexane
cyclohexane
Other hexanes
heptanes
methylcyclohexane
224-TMP
Benzene
Toluene
Ethylbenzene
Xylenes
C8+ Heavies
10.436
251.77
`2205505.25
1102.75
2.802
4.824
0.738
2.574
0.788
0.882
0.062
0.289
0.052
0.399
0.864
0.124
0.016
0.030
0.069
0.018
0.034
0222
67.61
592226.90
296.11
509.78
_9410'.
116.39
1019553.74
17.81
62.11
19.00
21.28
155993.93
544087.16
166461.98
186381.94
78.00
272.04
SCHEIIINUM
gmletadmtgast
70.13
86.18
84.16
86.18
1.51
6.96
1.24
9.62
13206.11
60997.91
10885.55
84256.89
83.23
93.19
6.60
30.50
G.
5.44
?ff
42.13
91.26
13.08
100.21
20.84
182520.17
0144
7!
98.19
114.23
78.12
92.15
2.99
0.39
0.71
1.67
0.43
0.82
5.36
26168.31
3379.88
6257.41
1.69
3.13
7.31
1.86
3.61
;07-51
14626.10
2
106.17
106.17
114.23
3724.80
7225.22
46956.22
23.48
VOC mass fraction: 0.4452 Total VOC (Uncontrolled)
26.92
Notes
Mole % from site -specific separator gas analysis collected on 8/1/2017.
Applicant states maximum vent rate of 12000 scf/hr, but requests a lower permit limit of 80.1 MMscf/yr.
This is about 6675 hours per year at the claimed maximum vent rate of 12000 scf/hr.
1266.34
17WE0740.CP1.xlsm
no gathering pips
s in.place.
Wirt Flat fo
Flaring Information
Equipment Description
Flare to combust low-pressure separator, heater treater, and vapor recovery tower as.
ratg of separat
organ
r wildcat
Manufacturer
Crimson Energy
Model
CE 1000
Serial Number
TBD
Gas Heating Value
1476.37
Btu/scf
Throughput
118257.237
MMBtu/yr
Overall Control
95.00%
)),ruse
Combustion emission factor source:
0.068 jib NOX/MMBtu
AP -42: Chapter 13.5
0.31 IIbCO/MMBtu
�Cylettes".
Below is a table summarizing the emission factors and resulting emissions calculated by the operator and used in the permit. As described in the
additional notes section below, the difference is likely due to rounding. This difference is small enough to be considered insignificant and thus
acceptable for permitting purposes.
Emissions Summary Table (Values used in permit)
<iS
123-9F49-004
17WE0740 CP1
'
Pollutant
Uncontrolled Emission Factor
Controlled Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
316'40.0
lb/MMscf
1582.00 lb/MMscf
1267.18 tpy
63.36 tpy
Gas Analysis
NOx
1106
lb/MMBTU
0.068 lb/MMBTU
4.02 tpy
4.02 tpy
AP -42
CO
- 11311
Ib/MMBTU
0.31 lb/MMBTU
18.33 tpy
18.33 tpy
AP -42
Benzene
: 78,13:'
lb/MMscf
3.906 lb/MMscf
6257 lb/yr
313 lb/yr
Gas Analysis
Toluene
' :; 182;56
lb/MMscf
9.129 lb/MMscf
14625 lb/yr
731 lb/yr
Gas Analysis
Ethylbenzene
31.;48..50
lb/MMscf
2.325 lb/MMscf
3725 lb/yr
186 lb/yr
Gas Analysis
Xylenes
,,,1+1:;-9 ,20
lb/MMscf
4.510 lb/MMscf
7225 lb/yr
361 lb/yr
Gas Analysis
n -Hexane
';:-781=.52'..
lb/MMscf
38.076 lb/MMscf
60998 lb/yr
3050 lb/yr
Gas Analysis
2,2,4-TMP
42:19
lb/MMscf
2.110 lb/MMscf
3379 lb/yr
169 lb/yr
Gas Analysis
Regulatory Applicability
AQCC Reaulation 1
This source is subject to the opacity requirements for flares in Section II.A.5:'No owner or operator of a smokeless flare or other
flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess
of 30% opacity.'
AQCC Reaulation 2
Section I.A applies to all emission sources. "No person, wherever located, shall cause or allow the emission of odorous air
contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits:
For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has
been diluted with seven (7) or more volumes of odor free air."
AQCC Regulation 7
Was the weft newly constructed, hydraulically fractured, or recompleted on or after August 1, 2014?
Yes
This separator is subject to Reg 7, Section XVII.G. and control requirements of Reg 7, Section XVII.B.2
Additional Notes:
The emission factors calculated in this preliminary analysis are not identical to the emission factors reported by the operator on the APEN. However, the difference
between the values is small enough as to be considered insignificant. The difference between these values is most likely due to rounding in the calculations. The
emission factors reported by the operator in the application will be used for permitting purposes.
The perm( will require a flow meter to monitor and record the volumetric flowrate of natural gas vented from the separator.
SCC CODING
SCC Code:
31000205
Emission Factors for Permit:
Uncontrolled (lb/MMscf vented)
NOx 100.39
CO
VOC
Benzene
Toluene 182.58
Ethylbenzene
Xylenes
n -Hexane
2,2,4-TMP 42.19
Controlled (lb/MMscf vented) Control Eff.
100.39
0%
0%
95%
457.67 457.67
31639.95 1582.00
78.11 3.91 95%
9.13 95%
2.33 95%
46.50
90.20 4.51 95%
761.52 38.08 95%
2.11 95%
17WE0740.CP1.xlsm
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Longs Peak Resources, LLC
123
9F49
Pismo 35-2-2-2CH
History File Edit Date
Ozone Status
11/212017
Attainment
EMISSIONS - Uncontrolled (tons per year
EMISSIONS With Controls (tons per year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous Permitted Facility
total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
. 0.0
0.0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TED
30.2
2.0
50.9
0.4
2.9
2.0
5.8
0.4
new point
002
17WE0738.XP
Loadout crude oil to tank trucks
4.3
-
0.1
4.3
0.1
XP due to less than 10,000 gal/d crude oil
003
17WE0739
Crude oil storage (1600 bbl)
0.7
453.6
3.2
17.7
0.7
22.7
3.2
0.9
SSEFs accepted
004
17WE0740
Separator venting
4.0
1,267.2
18.3
48.1
4.0
63.4
18.3
2.4
SSEFs accepted
005
17W51074
Produced water storage (800 bbl)
29.4
3.2
1.5
0.2
State EFs
APEN-Exempt / Insignificanis
XA
Heater -Treater
0.2
0.1
0.0
0.2
0.1
0.0
from Aug 2017 Form 102
XA
Fugitives
0.1
0.0
0.1
0.0
from Aug 2017 Form 102
XA
FLR Tank
0.7
0.0
0.7
0.0
from Aug 2017 Form 102; separate tank battery is
XA due to emissions
XA
Loadout from FLR Tank
0.1
0.0
0.1
0.0
from Aug 2017 Form 102; loadout activity is XA
due to emissions
XA
"GEN2": PSI 11.1L
1.7
0.1
2.9
0.0
0.2
0.1
0.3
0.0
from Aug 2017 Form 102; used only during startup
of pump
FACILITY TOTAL
0.0
0.0
0.0
0.0
36.9
1,757.4
0.1
75.4
69.5
0.0
0.0
0.0
0.0
8.0
94.8
0.1
27.8
3.9
VOC: Syn Minor (PSI) and OP)
NOx: Minor (PSD and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor n -hex and Total
HH: Syn Minor + affected Area
ZZZZ: Syn Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
350
1,752.2
0.0
72.4
69.4
0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
3.9
Excludes units exempt from permits/APENs
(A) Change In Permitted Emissions
0.0
0.0
0.0
0.0
7,6
89.6
0.0
27.4
pubcom required based on new syn minor limits
Note 1
Total VOC Facility
(A) Change in Total Permitted VOC
Emissions (point and fugitive)
emissions (point and fugitive)
94.9
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
89.6
Initial application rec'd July 2017; wholesale revisions rec'd Aug 31 2017; minor re -revision received Oct 2017.
Note 2
Page 1 of 2
Printed 11/6/2017
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Longs Peak Resources, LLC
County AIRS ID 123
Plant AIRS ID 9F49
Facility Name Pismo 35-2-2-2CH
Emissions - uncontrolled (Ibs per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
'Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
4948
1509 ,
70
447
27114
1244
17.7
004
17WE0740
Separator venting
6257
14625
3725
7225
60998
3379
48.1
005
17WE1074
Produced water storage (800 bbl)
1569
4930
3.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTAL,tpy)
0.3
0.0
0.0
6.4
8.1
1.9
3.8
46.6
0.0
2.3
0.0
0.0
69.5
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (Ibs per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
247
75
3
22
1356
62
0.9
004
17WE0740
Separator venting
313
731
186
361
3050
169
2.4
005
17WE1074
Produced water storage (800 bbl)
78
246
0.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
-
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTALJtpy)
0.3
0.0
0.0
0.3
0.4
0.1
0.2
2.4
0.0
0.1
0.0
0.0
3.9
2
1239F49.xlsx
11/6/2017
Colorado Air Permitting Project
Project Details
Review Engineer: Andy: Gruel
Package #: 366196
Received Date: 7/14/
Review Start Date: 1I/212O17
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
Physical Address/Location:
Type of Facility:
What industry segment?
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant? carbon Monoxide (CO)
ised Oct 2017
Section 02 - Emissions Units In Permit Application
Weld
Quadrant
Section
Township
Range
NW:NE,
3
NWNE quadrant of Section 35, Township 12N, Range 66W, in Weld County, Colorado
b.
articulate Matter (PM)
❑hone (NOx & VOC)
AIRS Point #
Emissions Source Type
Equipment
Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
TANKS ....
Section 03 - Description of Project
CP1.
CP
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
ec'f 8/31/17 once si
anew E&P site in far:0
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) O O ❑ O O ❑
Title V Operating Permits (OP) O O O O O O O 0
Non -Attainment New Source Review (NANSR) O O
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non-Attaiiment New Source Review (NANSR)
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑ ❑ ❑ O O
❑ ❑ ❑ ❑ O O ❑ ❑
❑ ❑
Produced Water Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRS ID:
County
Plant
DOS
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
T ao(2)4od.bbBihiudxi
Emission Control Device ThdosedrAmbusiar 'CA -insets
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Produced Water Throughput =
Requested Permit Limit Throughput = •
Potential to Emit (PTE) Produced Water
Throughput =
Barrels (bbl) per year
Barrels (bbl) per year
Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
See Section 08 for discussion of estimation of NOx and CO emissions.
Section 04- Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Actual Produced Water Throughput While Emissions Controls Operating =
Pollutant
Pollutant
Section OS - Emissions
Produced Water Tank
Uncontrolled
Controlled
(lb/bbl)
(Ib/bbl)
(Produced Water
Throughput)
(Produced
Water
Throughput)
Control Device
Uncontrolled Uncontrolled
(Ib/MMBtu)
(lb/bbl)
(waste heat
combusted)
(Produced
Water
Throughput)
Emission Factor Source
Emission Factor Source
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
VOC
PM10
PM2.5
NOx
CO
29.4
0.0
0.0
29.35
1.47 '
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1569
0
0
1569
78
4930
0
0
4930
246
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII.C.2
Regulation 6, Part A, NIPS Subpart 0000a
Storage Tank is not subject to NIPS 0000a
(See regulatory applicability worksheet for detailed analysis)
1 of 2 K:\PA\2017\17WE1074.CP1.xlsm
Produced Water Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Reouirements
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid water sample drawn
at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered
representative which generally means site -specific and collected within one year of the application received date.
However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to
use an older site -specific sample.
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section OS Technical Analysis Notes
t estimated NOxand'CO mn sions.hate t.on thed2005CDPxE rrtemS (1i
storage and not produced. •), I calculated Non and CO'emissio s.a
NNOn:; OA037't'29.35 a 20 ),C :,;,7,;.0319r NOn /:.
CO. 60094:''20.35•.zoUt1=5..
Roth resultsare:below thnAPEN`threshold inthe attainment area;:"s
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
005
0037 lb Nox/lhVOC,';and'0,00941UCOj)F
Process # SCC Code
01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses
me highly conservative{becmuse th e
condensate
Uncontrolled
Emissions
Pollutant Factor Control % Units
VOC 6.2 95 lb/1,000 gallons liquid throughput
Benzene 0.17 95 lb/1,000 gallons liquid throughput
n -Hexane 0.52 95 lb/1,000 gallons liquid throughput
2 of 2
K:\PA\2017\17 W E1074.CP1.xlsm
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
Longs Peak Resources, LLC
123
9F49
Pismo 35-2-2-2CH
History File Edit Date
Ozone Status
11/212017
Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS
ID
PERMIT
Description
PM1D
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.D
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
17WE0737
"GENI" PSl 11.1L, sn: TED
30.2
2.0
50.9
0.4
2.9
2.0
5.8
0.4
new point
002
17WE0738.XP
Loadout crude oil to tank trucks
4.3
0.1
4.3
0.1
XP due to less than 10,000 gelid crude oil
003
17WE0739
Crude oil storage (1600 bbl)
0.7
453.6
3.2
17.7
0.7
22.7
3.2
0.9
SSEFs accepted
004
17WE0740
Separator venting
4.0
1,267.2
18.3
48.1
4.0
63.4
18.3
2.4
SSEFs accepted
005
17WE1074
Produced water storage (800 bbf)
29.4
3.2
1.5
0.2
State EFs
APEN-Exempt / Insignificants
XA
Heater -Treater
0.2
0.1
0.0
0.2
0.1
0.0
from Aug 2017 Form 102
XA
Fugitives
0.1
0.0
0.1
0.0
from Aug 2017 Form 102
XA
FLR Tank
0.7
0.0
0.7
0.0
from Aug 2017 Form 102; separate tank battery is
XA due to emissions
XA
Loadout from FLR Tank
0.1
0.0
0.1
0.0
from Aug 2017 Form 102; loadout activity is XA
due to emissions ,
XA
"GEN2": PSI 11.1L
1.7
0.1
2.9
0.0
0.2
0.1
0.3
0.0
from Aug 2017 Form 102; used only during startup
of pump
FACILITY TOTAL
-
0.0
0.0
0.0
0:0
36.9
1,757.4
0.1
-
75.4
69.5
0.0
0.0
0.0
0.0
8.0
94.8
0.1
27.8
3.9
VOC: Syn Minor (PSD and OP)
NOx: Minor (PSD and OP)
CO: Minor (PSD and OP)
HAPS: Syn Minor n -hex and Total
HH: Syn Minors affected Area
ZZZZ: Syn Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
35.0
1,752.2
0.0
72.4
69.4
- 0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
3.9
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.0
0.0
0.0
0.0
7.6
89.6
0.0
27.4
Pubcom required based on new syn minor limits
Note 1
Total VOC Facility
(A) Change in Total Permitted VOC
Emissions (point and fugitive
emissions (point and fugitive)
94.9
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
89.6
Initial application rec'd July 2017; wholesale revisions rec'd Aug 31 2017; minor re -revision received Oct 2017.
Note 2
Page 1 oft
Printed 11/6/2017
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name Longs Peak Resources, LLC
County AIRS ID 123
Plant AIRS ID 9F49
Facility Name Pismo 35-2-2-2CH
Emissions - uncontrolled (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
(Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
4948
1509
70
447
27114
1244
17.7
004
17WE0740
Separator venting
6257
14625
3725
7225
60998
3379
48.1
005
17WE1074
Produced water storage (800 bbl)
1569
4930
3.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTAL (tpy)
0.3
0.0
0.0
6.4
8.1
1.9
3.8
46.6
0.0
2.3
0.0
0.0
69.5
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with controls (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
!Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
17WE0737
"GEN1" PSI 11.1L, sn: TBD
561
76
72
43
15
84
0.4
002
17WE0738.XP
Loadout crude oil to tank trucks
15
132
0.1
003
17WE0739
Crude oil storage (1600 bbl)
247
75
3
22
1356
62
0.9
004
17WE0740
Separator venting
313
731
186
361
' 3050
169
2.4
005
17WE1074
Produced water storage (800 bbl)
78
246
0.2
0.0
APEN-Exempt / Insignificants
0.0
XA
Heater -Treater
0.0
XA
Fugitives
0.0
XA
FLR Tank
0.0
XA
Loadout from FLR Tank
0.0
XA
"GEN2": PSI 11.1L
0.0
TOTALJtpy)
0.3
0.0
0.0
0.3
0.4
0.1
0.2
2.4
0.0
0.1
0.0
0.0
3.9
2
1239F49.xlsx
11/6/2017
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
PERMIT NO:
17WE0737
CONSTRUCTION PERMIT
Issuance 1
DATE ISSUED:
ISSUED TO: Longs Peak Resources, LLC
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as Pismo 35-2-2-2CH, located in NWNE Section 35 T12N R66W,
in Weld County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment ID
AIRS
Point
Description
GEN1
001
One (1) PSI, Model 11.1L, Serial Number To Be
Determined, natural gas -fired, turbo -charged, 4SRB
reciprocating internal combustion engine, site rated at 302
horsepower. This engine shall be equipped with a non-
selective catalytic reduction (NSCR) system and air -fuel ratio
control. This emission unit powers a generator.
This engine may be replaced with another engine in accordance with the temporary engine
replacement provision or with another PSI 11.1L 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 THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than
fifteen days of the latter of commencement of operation or issuance of this permit,
by submitting a Notice of Startup form to the Division. The Notice of Startup form
may be downloaded online at https://www.colorado.gov/pacific/cdphe/other-air-
permittinq-notices. Failure to notify the Division of startup of the permitted source is a
violation of Air Quality Control Commission (AQCC) Regulation No. 3, Part B, Section
III.G.1 and can result in the revocation of the permit.
AIRS ID: 123/9F49/001 Page 1 of 15
NGEngine Version 2014-1
Public Health and Environment
Air Pollution Control Division
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. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
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.
(Reference: Regulation No. 3, Part B, Section III.E.)
5. The following information shall be provided to the Division within fifteen (15) days of the
latter of commencement of operation or issuance of this permit.
•
•
•
.
•
manufacture date
construction date
order date
date of relocation into Colorado
manufacturer
model number
• serial number
This information shall be included with the Notice of Startup submitted for the equipment.
(Reference: Regulation No. 3, Part B, III.E.)
6. 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
7. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Monthly Limits:
Facility
Equipment ID
AIRS
Point
Pounds per Month
Emission Type
NO„
VOC
CO
GEN1
001
496
347
991
Point
(Note: Monthly limits are based on a 31 -day month.)
The owner or operator shall calculate monthly emissions based on the calendar month.
AIRS ID: 123/9F491001
Page 2 of 15
Public Health and Environment
Air Pollution Control Division
Facility -wide emissions of each individual hazardous air pollutant shall be less than
1,359 lb/month.
Facility -wide emissions of total hazardous air pollutants shall be less than 3,398
lb/month.
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission Type
NO.
VO C
CO
GEN1
001
3.0
2.1
5.9
Point
ee "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 be less than 8.0
tpy.
Facility -wide emissions of total hazardous air pollutants shall be less than 20.0 tpy.
During the first twelve (12) months of operation, compliance with both the monthly and
annual emission limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
8. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
GEN1
001
Non -selective catalytic reduction (NSCR) system
and air/fuel ratio controller
NOx and CO
PROCESS LIMITATIONS AND RECORDS
9. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
AIRS ID: 123/9F49/001
Page 3 of 15
Process/Consumption Limits
Public Health and Environment
Air Pollution Control Division
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual
Limit
Monthly Limit
(31 days)
GEN1
001
Consumption of natural gas as a fuel
18.53
MMscf/yr
1.58
MMscf/month
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 calculate monthly process rates based on the calendar
month.
During the first twelve (12) months of operation, compliance with both the monthly and
annual throughput limitations is required. After the first twelve (12) months of operation,
compliance with only the annual limitation is required.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and AIRS ID point number (e.g. 123/9F49/xxx) shall be marked on
the subject equipment for ease of identification. (Reference: Regulation Number 3, Part
B, III.E.) (State only enforceable)
11. 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 I I.A.1. & 4.)
12. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
OPERATING & 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 your O&M plan are subject to Division approval prior to
implementation. (Reference: Regulation No. 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.
AIRS ID: 123/9F49/001 Page 4 of 15
Public Health and Environment
Air Pollution Control Division
Periodic Testing Requirements
15. This engine is subject to the periodic testing requirements as specified in the operating
and maintenance (O&M) plan as approved by the Division. Revisions to your O&M plan
are subject to Division approval. Replacements of this' unit completed as Alternative
Operating Scenarios may be subject to additional testing requirements as specified in
Attachment A.
ADDITIONAL REQUIREMENTS
16. A revised -Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. 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.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
d. Whenever a permit limitation must be modified; or
e. No later than 30 days before the existing APEN expires.
f. Within 14 calendar days of commencing operation of a permanent replacement
engine under the alternative operating scenario outlined in this permit as
Attachment A. The APEN shall include the specific manufacturer, model and
serial number and horsepower of the permanent replacement engine, the
appropriate APEN filing fee and a cover letter explaining that the owner or
operator is exercising an alternative -operating scenario and is installing a
permanent replacement engine.
17. Federal regulatory program requirements (i.e. PSD or NANSR) shall apply to this source
at any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
AIRS ID: 123/9F49/001 Page 5 of 15
Public Health and Environment
Air Pollution Control Division
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 No. 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 No. 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
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
24. 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.
AIRS ID: 123/9F491001 Page 6 of 15
Public Health and Environment
Air Pollution Control Division
By:
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Longs Peak Resources, LLC.
AIRS ID: 12319F491001 Page 7 of 15
Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 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/agcc-reqs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (lb/yr)
001
Formaldehyde
50000
561
Yes
561
Methanol
67561
84
No
84
Acetaldehyde
75070
76
No
76
Acrolein
107028
72
No
72
Benzene
71432
43
No
43
1,3 -Butadiene
106990
18
No
18
Toluene
108883
15
No
15
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
CAS
Pollutant
Emission
Uncontrolled
Ib/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
Ib/MMBtu
Factors —
g/bhp-hr
NOx
2.2100
10.40
0.2130
1.00
CO
3.7200
17.40
0.4262
2.00
VOC
0.1493
0.70
0.1493
0.70
50000
Formaedehyd
0.0205
0.10
0.0205
0.10
67561
Methanol
0.0031
0.01
0.0031
0.01
75070
Acetaldehyde
0.0028
0.01
0.0028
0.01
107028
Acrolein
0.0026
0.01
0.0026
0.01
71432
Benzene
0.0016
0.01
0.0016
0.01
AIRS ID: 12319F491001
Page 8 of 15
Public Health and Environment
Air Pollution Control Division
CAS
Pollutant
Emission
Uncontrolled
lb/MMBtu
Factors -
g/bhp-hr
Emission
Controlled
lb/MMBtu
Factors —
g/bhp-hr
106990
1'3
Butadiene
0.0007
0.003
0.0007
0.003
108883
Toluene
0.0006
0.003
0.0006
0.003
Emission factors are based on a Brake -Specific Fuel Consumption Factor of 10339 Btu/hp-hr, a
site -rated horsepower value of 302, and a fuel heat value of 1476.4 Btu/scf.
Emission Factor Sources:
CAS
Pollutant
Uncontrolled EFSource
Controlled EF Source
NOx
AP -42; Table 3.2-3 (7/2000);
Natural Gas
Claimed by Applicant
CO
AP -42; Table 3.2-3 (7/2000);
Natural Gas
Claimed by Applicant
VOC
Manufacturer's spec
No Control
50000
Formaldehyde
y
AP -42; Table 3.2-3 (7/2000);
Natural Gas -
No Control
67561
Methanol
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
75070
Acetaldehyde
y
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
107028
Acrolein
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
71432
Benzene
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
106990
1,3 -Butadiene
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
108883
Toluene
AP -42; Table 3.2-3 (7/2000);
Natural Gas
No Control
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 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/fr18ia08.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.qov/ttn/atw/area/fr18ja08.pdf
Additional information regarding area source standards can be found on the EPA website at:
http://www. epa. qov/ttn/atw/area/arearu les. htm I
9) This facility is classified as follows:
Applicable
Status
AIRS ID: 12319F491001
Page 9 of 15
Public Health and Environment
Air Pollution Control Division
Requirement
Operating Permit
Synthetic Minor Source of: VOC, HAPs (n -hexane, and total)
PSD
Synthetic Minor Source of: VOC
MACT ZZZZ
Area Source Requirements: Applicable
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, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
11) A self certification form and guidance on how to self -certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 12319F491001 Page 10 of 15
Public Health and Environment
Air Pollution Control Division
ATTACHMENT A:
ALTERNATIVE OPERATING SCENARIOS
RECIPROCATING INTERNAL COMBUSTION ENGINES
October 12, 2012
2. 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.
2.1 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 2.1.2 and make
them available to the Division upon request.
2.1.1 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 22.
AIRS ID: 12319F491001 Page 11 of 15
Public Health and Environment
Air Pollution Control Division
2.1.2 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 2.2.
The AOS cannot be used for the permanent replacement of an entire engine at any source that is
currently a major stationary source for purposes of Prevention of Significant Deterioration or Non -
Attainment Area New Source Review ("PSD/NANSR") unless the existing engine has emission limits that
are below the significance levels in Reg 3, Part D, II.A.42.
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 operating scenario and is installing a permanent
replacement engine, and a copy of the relevant Applicability Reports for the replacement engine.
Example Applicability
Reports can be found at https://www.colorado.gov/pacific/cdphe/alternate-operating-scenario-aos-
reporting-forms. This submittal shall be accompanied by a certification from the Responsible Official
indicating that "based on the information and belief formed after reasonable 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.
Nothing in this AOS shall preclude the Division from taking an action, based on any permanent engine
replacement(s), for circumvention of any state or federal PSD/NANSR requirement. Additionally, in the
event that any permanent engine replacement(s) constitute(s) a circumvention of applicable PSD/NANSR
requirements, nothing in this AOS shall excuse the owner or operator from complying with PSD/NANSR
and applicable permitting requirements.
2.2 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.
AIRS ID: 12319F491001 Page 12 of 15
Public Health and Environment
Air Pollution Control Division
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.
2.3 Applicable Regulations for Permanent Engine Replacements
2.3.1 Reasonably Available Control Technology (RACT): Reg 3, Part B § II.D.2
All permanent replacement engines that are located in an area that is classified as
attainment/maintenance or nonattainment must apply Reasonably Available Control Technology (RACT)
for the pollutants for which the area is attainment/maintenance or nonattainment. Note that both VOC and
NOX are precursors for ozone. RACT shall be applied for any level of emissions of the pollutant for which
the area is in attainment/maintenance or nonattainment, except as follows:
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 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 (§ 60.331) and 40 CFR Part 72 (§ 72.2), natural gas contains
20.0 grains or less of total sulfur per 100 standard cubic feet.
2.3.2 Control Requirements and Emission Standards: Regulation No. 7, Sections XVI. and XVII.E (State -
Only conditions).
AIRS ID: 123/9F49/001 Page 13 of 15
Public Health and Environment
Air Pollution Control Division
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 2.1.2.
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:
Max Engine HP
Construction or
Relocation Date
Emission Standards in G/hp-hr
NOx
CO
VOC
100<Hp<500
January 1, 2008
January 1, 2011
2.0
1.0
4.0
2.0
1.0
0.7
500≤Hp
July 1, 2007
July 1, 2010
2.0
1.0
4.0
2.0
1.0
0.7
The source shall submit copies of the relevant Applicability Reports required under Condition 2.1.2.
2.3.3 NSPS for stationary spark ignition internal combustion engines: 40 CFR Part 60, Subpart JJJJ
A permanent replacement engine that is manufactured on or after 7/1/09 for emergency engines greater
than, 25 hp, 7/1/2008 for engines less than 500 hp, 7/1/2007 for engines greater than or equal to 500 hp
except for lean burn engines greater than or equal to 500 hp and less than 1,350 hp, and 1/1/2008 for
lean burn engines greater than or equal to 500 hp and less than 1,350 hp are subject to the requirements
of 40 CFR Part 60, Subpart JJJJ. An analysis of 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 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 2.2, if approved in advance by the Division, provided that such test is conducted
within the time frame specified in Condition 2.2.
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).
AIRS ID: 123/9F49/001 Page 14 of 15
Public Health and Environment
Air Pollution Control Division
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, § l.B (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.
2.3.4 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 2.2, if approved in advance by the Division, provided that such test is conducted within the time
frame specified in Condition 2.2.
2.4 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.
AIRS ID: 123/9F49/001 Page 15 of 15
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE0739
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Longs Peak Resources, LLC
Pismo 35-2-2-2CH
123/9F49
NWNE Section 35 T12N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TANKS
003
Four (4) 400 -barrel fixed roof storage
vessels used to store crude oil.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division'. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
3. is permi W all a owner • • ator of t e for wh this permit was issued:
structiotion o ion of thi ource within 18 months
issuan of thi onstru on permit or e date on which such
sch - uled to •men as set forth � the permit application
a s.ciated with i •-rmi "ii •iscontinu-s •ns u i.n for a peno.. 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 I I .A.4. )
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO„
VOC
CO
TANKS
003
---
---
22.7
3.3
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.
7. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TANKS
003
Enclosed Flare (Crimson Energy, CE 1000)
VOC and HAP
COLORADO
Air Pollution Control Division
Page 2 of 7
8.
ro ssing rats listed below. Monthly
ned by the ow '''r or operator and made
ulation N .,. Part B, II.A.4.)
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
TANKS
003
Crude Oil throughput
82,694 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
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9F49/xxx)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the date that
the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
COLORADO
IMr Pollution Control Division
3
,:rezN.xrx :tot PLO Heaftn &Envircameflt
Page 3 of 7
COMPL
ni is esting equiremen s
Divisio al prior
(Regulation Number 3,
15. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
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 -
,COLORADO
I Air Pollution Control Division
Depotmemd3tliA C^,unmet.
Page 4 of 7
u
C Regul
e operati
is with
e co
ved by
. De i • " obtaim
mber 3
vity co
ions o
lviSi
is
, Section
and has
e permit. On
it will provide
rization t
G. Final authorization
en verified by the APCD
self -certification of all
tten documentation of
e te 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 Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Longs Peak Resources, LLC.
!COLORADO
Air Pollution Control Division
Page 5 of 7
Notes t� ermit Ho y r at 1 11 if this pe uance:
1) Th -rmit hole is r ire3 _+ pay fe tim for this p it. An invoice for these
fee 'II be l ; daft the . ;;, it is ued. T .ermit elder shall pay ,x invoice within 30 days
ay t result i tion of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of
any malfunction condition which causes a violation of any emission limit or limits stated in this permit
as soon as possible, but no later than noon of the next working day, followed by written notice to
the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation.
See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
4948
247
Toluene
108883
1509
75
Ethylbenzene
100414
70
3
Xylenes
1330207
447
22
n -Hexane
110543
27114
1356
2,2,4-
Trimethylpentane
540841
1244
62
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 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
N0x
0.068
0.068
AP -42 Section 13.5
CO
0.31
0.31
V0C
10.97
0.55
EF&P TANKS model
based on site -
specific
pressurized liquid
sample collected
8/1/2017.
71432
Benzene
0.060
0.003
108883
Toluene
0.018
0.001
100414
Ethylbenzene
0.001
0.00004
1330207
Xylene
0.005
0.0003
110543
n -Hexane
0.328
0.016
540841
2,2,4-
Trimethylpentane
0.015
0.001
COLORADO
Air Pollution Control Division
Page 6 of 7
actors for nt are ba. on e flare co of efficiency of 95%. NOx
based on :s heat v - • ''864 Btu/s« _ nd a GOR of 87.18 scf/bbl
model ed on':-specif amp e.)
6) I - th 5 - h Air sion Noti - ) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (n -hexane, and total)
PSD
Synthetic Minor Source of: VOC
MACT HH
Area Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A - Appendix
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
Air Pollution Control Division
Ur i:ixtiRw - th & Erwirhnment
Page 7 of 7
Permit number:
Date issued:
Issued to:
ADC?
ri contra
tc Heal
CONSTRUCTION PERMIT
17WE0740
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Longs Peak Resources, LLC
Pismo 35-2-2-2CH
123/9F49
NWNE Section 35 T12N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
SEPARATOR
004
2 -phase Vertical Separator controlled by an
enclosed flare because no gas gathering
pipeline is available.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 7
3. , expi er or oper e source A i this permi - s issued:
enc o f tion/modif fi •peration - is ource withi 8 months
e da •f is ce of t constrk on per or the date on ich such
r activi3 € was suled commenth in the perms • •lication
a e• with thi " = ; (ii) -s cons od of eigh - •'the 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. Within one hundred and eighty days (180) after issuance of this permit, the operator shalt install
a flow meter to monitor and record volumetric flow rate of natural gas vented from each
separator covered by this permit. Until the flow meter is installed, the operator shall monitor
and record crude oil produced through the separator and estimate the gas flow rate based on
standard cubic feet (scf) per barrel (bbl) of 969 scf/bbl estimated in the permit application.
5. 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.)
6. 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
7. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4. )
Annual Limits:
s permit s
does not c
er either,
stru '.
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
SEPARATOR
004
---
4.1
63.4
18.4
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder shall calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
8. The emission points in the table below shall be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
SEPARATOR
004
Emissions from the Separator are routed to an
Enclosed Flare (Crimson Energy, CE 1000).
VOC and HAP
COLORADO
I Air Pollution Co€'ttrol Division
j e artr,v kt:# NKr, tip ath E':,vncm.rtent
Page 2 of 7
9. s source s _.° be li gf ed t e follows "} :' �...,processt ate s listed be :. Monthly
ctual ocessi .tes sh ' be main ed by E owner or operate :nd made
he Di insp eque I. a t ber 3, Par
•
Process Limits
Facility
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
SEPARATOR
004
Natural Gas Venting
80.1 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.
10. Upon installation of the flow meter, the owner or operator shall continuously monitor and record
the volumetric flow rate of natural gas vented from the separator(s) using the flow meter. The
owner or operator shall use monthly throughput records to demonstrate compliance with the
process limits contained in this permit and to calculate emissions as described in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
11. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/9F49/xxx)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III. E.) (State only enforceable)
12. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall
allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity
for a period or periods aggregating more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.5.)
13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
14. 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.
15. The separator covered by this permit is subject to Regulation 7, Section XVII.G. (State Only). On
or after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the date of first production by air pollution
control equipment that achieves an average hydrocarbon control efficiency of 95%. If a
combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons.
OPERATING Et MAINTENANCE REQUIREMENTS
[COLORADO
Mr Control Division
Data4rr t t PO)teW F E 9' n i',.T.n4"0nment
Page 3 of 7
16.
are sub
ection III.
owner or
ecord kee
going b
na
shall foil• ' u Est recent o ating and
t appro •y e Division, order to
equire-„`ts of this permit 3 ;visions to
ation. (Regulatio umber 3,
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen minute period during normal
operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16)
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. 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.
20. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such
time that this source becomes major solely by virtue of a relaxation in any permit condition. Any
relaxation that increases the potential to emit above the applicable Federal program threshold
will require a full review of the source as though construction had not yet commenced on the
source. The source shall not exceed the Federal program threshold until a permit is granted.
(Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
COLORADO
Air Pollution Control Di*risiort
Page 4 of 7
21.
s permit
uest. The
ber 3, P.
ised m_
le for ins•„ ion upon
s prided in AQC egulation
ership and the s »' ittal of a
22. 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.
23. 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.
24. 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.
25. 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.
26. 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.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to Longs Peak Resources, LLC.
COLORADO
Air Pollution Control Division
I Dep.Srtrr,kt Herah 6, En smorxnent
Page 5 of 7
Notes t
1) The
fee
rmit Hold
rmit holde
II be issu
permit iss
ees forth • • time for s pe it. An invo for these
ssued e permi lder shay the invoice w n 30 days
e invure _... invoice evocationermit.
(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-reps
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
Equipment ID
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(Ib/yr)
Controlled
Emissions
(Ib/yr)
SEPARATOR
004
Benzene
71432
6257
313
Toluene
108883
14625
731
Ethylbenzene
100414
3725
186
Xylenes
1330207
7225
361
n -Hexane
110543
60998
3050
2,2,4
Trimethylpentane
540841
3379
169
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 004:
CAS #
Pollutant
Uncontrolled
Emission Factors
(lb/MMscf)
Controlled
Emission Factors
(lb/MMscf)
Source
NOx
100.39
100.39
AP -42 Section 13.5
CO
457.67
457.67
VOC
31639.95
1582.00
Displacement
Equation based on a
site -specific gas
sample collected
August 1, 2017
71432
Benzene
78.11
3.91
108883
Toluene
182.58
9.13
100414
Ethylbenzene
46.50
2.33
1330207
Xylene
90.20
4.51
110543
n -Hexane
761.52
38.08
:COLORADO
Air Pollution Control Division
Page 6 of 7
S #
P Uncontr• ed
Emission .,:.-
(lb/ k= cf)
Contr
Emission o ;
(lb/ f)
S. e
m_
- ollut
3�
2,2
Trimethy pen ane
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. N0x
and CO emissions are based on a gas heating value of 1476.37 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 APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, HAPs (n -hexane, and total)
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, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
COLORADO
3 Air Pollution Cannot Division
i
l em- y_≥ ;;t PUbl We:AM n ss Es re6nretent
Page 7 of 7
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
17WE1074
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General
Description:
Issuance: 1
Longs Peak Resources, LLC
Pismo 35-2-2-2CH
12319F49
NWNE Section 35 T12N R68W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
PROD_WTR
005
Two (2) 400 barrel fixed roof storage vessels
used to store produced water.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission
and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general
terms and conditions included in this document and the following specific terms and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the
latter of commencement of operation or issuance of this permit, by submitting a Notice of
Startup form to the Division for the equipment covered by this permit. The Notice of Startup
form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting-
notices. Failure to notify the Division of startup of the permitted source is a violation of Air
Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result
in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance
of this permit, compliance with the conditions contained in this permit shall be demonstrated to
the Division. It is the owner or operator's responsibility to self -certify compliance with the
conditions. Failure to demonstrate compliance within 180 days may result in revocation of the
permit. A self certification form and guidance on how to self -certify compliance as required by
this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-
certification. (Regulation Number 3, Part B, Section III.G.2. )
'COLORADO
Air Pollution Control Division
E it
Page 1 of 7
3. e owner �� ator of •�� ce for w this permit was issued:
nstructio �:, ation o�pe �tion of th source within 18 months
issuan g of th° constr ion permit o he date on which such
sch mme as set forth the permit application
iated with r .ermi , i •iscontinu- •n" uc ion for a . "" •• •f eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated completion
date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section
III.F.4.)
4. The operator shall complete all initial compliance testing and sampling as required in this permit
and submit the results to the Division as part of the self -certification process. (Regulation
Number 3, Part B, Section III.E.)
5. The operator shall retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part
B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
PROD_WTR
005
---
---
1.5
---
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.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
PROD_WTR
005
Enclosed Flare (Crimson Energy, CE 1000)
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.)
COLORADO
Air Pollution Control Division
Page 2 of 7
ced
throughput
4,081 barre s
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 ten digit AIRS ID number assigned by the Division (e.g. 123/9F49/xxx)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part
B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7, Section
XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is
used to control emissions of volatile organic compounds to comply with Section XVII, it shall be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation
from the outside of the enclosed flare or combustion device, or by other convenient means
approved by the Division, determine whether it is operating properly. This flare must be equipped
with an operational auto -igniter according to the following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with an
operational auto -igniter upon installation of the combustion device;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section
XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to
the Division upon request. This control requirement must be met within 90 days of the date that
the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2.
OPERATING Et MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the 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
COLORADO
Air Pollutitm Control Division
, ni,Ment
Page 3 of 7
15.
mea
eater an o •ual. one
era` ion. (Regu a i Nu = ction
Periodic Testing Requirements
ith opa
termine
ns of smoke f
n fifteen-mi
VII.A.16
y standards, using EPA
presence or absence of
any period or periods of
e period during normal
16. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
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
permitmust be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation of
such final authorization. Details for obtaining final authorization to operate are located in the
Requirements to Self -Certify for Final Authorization section of this permit.
COLORADO
I Air Pollution Control Division
DeDas-te_°sat ut htb€ Y er ; %.'a yuc r s rtC
Page 4 of 7
20.
is permi
e owner
stallatio
re
nd
ions
equipment
nce upo
nd is c
erat of t ` sourc
e by own or oper
rati• • ivity
pleteness information supplied by
t of the tivity, or construction,
dance with information and with
er or operator ents. It is valid only for
ica ° y 1' 'ntified on ' ermit.
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 ob initio. This permit may be revoked
at any time prior to self -certification and final authorization by the Air Pollution Control Division
(APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air
Quality Control Commission (AQCC), including failure to meet any express term or condition of
the permit. If the Division denies a permit, conditions imposed upon a permit are contested by
the owner or operator, or the Division revokes a permit, the owner or operator of a source may
request a hearing before the AQCC for review of the Division's action.
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 Division in writing requesting
a cancellation of the permit. Upon notification, annual fee billing will terminate.
24. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Andy Gruel, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This issuance
Issued to Longs Peak Resources, LLC.
COLOR ADO
Air Pollution Control Division
v E vrr°mry
Page 5 of 7
Notes tof this p: uance:
1) Th pay fe for this i mit. An invoice for these
fee ill be l daft the it is sued. T � perms 'older shall pa e invoice within 30 days
ay t result i ation 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-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
005
Benzene
71432
1569
78
n -Hexane
110543
4930
246
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:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
0.262
0.0131
State Default
Emission Factor
for Weld County
71432
Benzene
0.007
0.0004
110543
n -Hexane
0.022
0.0011
Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
COLORADO
IAir Pollution Control Division
•p tr,o +.;r Pub , 1.1eath.n Erzurrnrrsts;t
Page 6 of 7
Synthetic Minor Source of: VOC, HAPs (n -hexane and total)
t
Operating Permit
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, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
iOLORADO
Air Pollution Control Division
_ ' t; ;emelt
Page 7 of 7
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:
147 Wc'737 AIRS ID Number: f 273 oof
[Leave blank unless APCD has a!leady assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Longs Peak Resources, LLC
Pismo 35-2-2-2CH
Site Location: NWNE Sec. 35, T12N, R66W
Mailing Address:
(Include Zip Code) 107;01 Melody Dr., Suite 515
Portable Source
Home Base:
Northglenn, CO 80234
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: David Clarkson
Phone Number: 303-997-5558
E -Mail Address2• 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.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
366190
ATCOLORADO
1...d'J,i g E
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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 0 Transfer of ownership4 ❑ 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
O Notification of Alternate Operating Scenario (AOS) permanent replacements
Additional Info Et 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 GPO2, as it does not contain a provision for AOS permanent replacements.
Section 3 - General4lnformation
su
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: 05/16/2017
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)
Normal Hours of Source Operation: 24
Seasonal use percentage: Dec -Feb: 25
❑ Yes ✓❑ No
hours/day 7 days/week 52 weeks/year
Mar -May: 25 June -Aug: 25 Sept -Nov: 25
_.._.._ _ __... COLORADO
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 2 l hr °`°,t,rt `,.at,",
Permit Number: AIRS ID Number: / /
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 4 - Engine Information
Engine
Function:
0 Primary and/or Peaking
El Pump ❑ Water Pump
❑ Emergency Back-up
El Other:
El Compression
What is the maximum number of hours this engine will be used for emergency
back-up power?
Engine Make: PSI Engine Model: 11.1L
0
Serial Number6: TBD
hours/year
What is the maximum designed horsepower rating? 302 hp What is the engine displacement? 1.85 l/cyl
What is the maximum manufacturer's site -rating? 302 hp
What is the engine Brake Specific Fuel Consumption at 100% Load?
Engine Features:
Cycle Type: ❑ 2 -Stroke ❑✓ 4 -Stroke
Ignition Source: ✓❑ Spark ['Compression
182
10331
kW
BTU/hp-hr
Combustion: ❑ Lean Burn
Aspiration: El Natural
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)
Is this engine equipped with a Low-N0X design? El Yes
Engine Dates:
What is the manufactured date of this engine? TBD
What date was this engine ordered? NA
❑✓ No
❑ Other:
❑✓ Rich Burn
❑✓ Turbocharged
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 ❑✓ No
If yes, provide the make, model, and serial number of the old engine below:
Engine Make:
Engine Model:
6 The serial number must be submitted if coverage under GP02 is requested.
Serial Number:
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
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)
40.96935/-104.74135
0 erato �f �
P
Stack ID No
� Discharge Height
Above Ground Level
rt
(Feet),
��r
Tempe
F
s
low late
c M
�.
Ve oci
(#t/se
GEN1
7
1350
1487
71
Indicate the direction of the Stack outlet: (check one)
El Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑� Circular
❑ Square/Rectangle
El Other (describe):
Interior stack diameter (inches):
8
❑ Upward with obstructing raincap
Interior stack diameter (inches): Interior stack depth (inches):
Section 6 - Fuel Data and Throughput Information
Fuel Use Rate @ 100% Load
(SCF/hour) .i
, Actual Annual Fuel Use
(MMSCFIye
Requested Annual Permit Limit's
'(MMSCE /year)
2115
18.53
From what year is the oat/al annual amount?
2017
Indicate the type of fuel useds:
El Pipeline Natural Gas (assumed fuel heating value of 1,020 BTU/scf
El Field Natural Gas Heating value: 1 ) L{ 3.6 BTU/scf
El Propane
❑ Landfill Gas Heating Value: BTU/scf
El Other (describe):
(assumed fuel heating value of 2,300 BTU/scf)
Heating Value (give units):
7 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
$ If fuel heating value is different than the listed assumed value, provide this information in the "Other" field.
woj COLORADO
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017 4 I AV ‘;f.U7F;W:.;=,
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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):
Pollutant
TSP (PM)
Primary Control Equipment Description
verall Requested Control.
Efficiency
(% reduction in emissions
PM10
PM2.5
SOx
N0x
VOC
NSCR
9,1163 10.36
CO
Other:
NSCR
es.4r g g . s y
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?
2017
Pollutant
Source
(AP -42,
Mfg. etc)
Uncontrolled
Basis
Units
Criteria Pollutant Emissions Inventory
TSP (PM)
1.94E-2
lb/MMBtu
AP -42
Actual Annual Emissions'
Uncontrolled;,
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
equested Annual Permi
Emission Limit(s)-4=1;
Uncontrolled
Emissions
(Tons/year)-"
0.28
0.28
PM10
PM2.5
1.94E-2
Ib/MMBtu
AP -42
0.28
0.28
1.94E-2
lb/MMBtu
AP -42
0.28
0.28
SOx
NOx
VOC
5.88E-4
lb/MMBtu
AP -42
0.008
0.008
2.21
0.70
lb/MMBtu
g/hp-hr
AP -42
Manufacturer
33o.23
2.04
562 so. r8
2.04
2. di
CO
3.72
lb/MMBtu
AP -42
Does the emissions source have any uncontrolled actual emissions of non -criteria ❑ Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑ No
If yes, please use the fpllowing table to report the non -criteria pollutant (HAP) emissions from source:
Formaldehyde
Acetaldehyde
5.83
Non -Criteria Reportable Pollutant Emissions Inventory
r'g Chemical
CI Abstract
"Service (CAS)
Number
50000
75070
2.05E-2
Emission Factor
Units
lb/MMBtu
Source
(AP -42,
Mfg. etc)`:,
AP -42
Actual Annual Emissions9
Uncontrolle
Emissions
d (Pou / )
(Pounds/
ear.
. .1 .561
"9. 561
Acrolein
Benzene
107028
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.
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete, true
and correct. If this is a registration for coverage under general permit GP02, I further certify that this source is and will
be operated In full compliance with each condition of general permit GP02.
7-/4V. /7
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
D 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 wW$152.90 and the General Permit
registration fee of $1,50D,';; if applicable to:
I..a
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
Form APCD-201 - Reciprocating Internal Combustion Engine APEN - Revision 1/2017
COLORADO
Crud, Oil Storage Tank(s) AP
Form APCD-210
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the 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-perrnits.
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:
11--wroR-3 et
AIRS ID Number: L /�— [11 � Or��
Section 1 - Administrative Information
Company Name:
Site Name:
Longs Peak Resources, LLC
Pismo 35-2-2-2CH
Site Location: NWNE Sec. 35, T12N, R66W
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
Northglenn, CO 80234
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact:
Phone Number:
E -Mail Address2:
David Clarkson
303-997-5558
dclarkson@vrtxep.com
I 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.
-E9 36w. a3
368539
!-, C O L O R A D O
Permit Number: AIRS ID Number:
r,L,. _ a c-.eri- t 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 tiling 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 -
El APEN submittal for permit exempt/grandfathered source
Additional Info Et Notes:
3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
4-400 bbl Crude Oil Tanks
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day
5/16/2017
7
❑✓ Exploration Et Production (EEtP) site
days/week
52
weeks/year
El Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
■
Yes
a
No
Are Flash Emissions anticipated from these storage tanks?
NI
Yes
■
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
•
p
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualCI
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
COLORADO
21
Permit Number:
AIRS ID Number:
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limit's
(bbl/year)
Crude Oil Throughput:
82694
From what year is the actual annual amount?
Average API gravity of sales oil: 37 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
RVP of sales oil:
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bb()
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TANKS
4
1600
3/17
4/17
Wells Serviced by this Storage Tank or Tank Batterys (MP Sites On
y)
API Number
Name of Well
Newly Reported Well
05 -123 - 40a
Pismo 35-2-2-2CH❑
- -
❑
■
_
■
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EaP 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)
40.96935/-104.74135
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(T)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Combustor
35
1000
Indicate the direction of the stack outlet: (check one)
0 Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
Circular Interior stack diameter (inches): 96
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
Interior stack depth (inches):
C� CO LOCCOO
3I �.
Permit Number: AIRS ID Number:
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
❑ Combustion
Device:
Pollutants Controlled: VOCs, HAPs
Rating: 1000 MSCfd MMBtu/hr
Make/Model: Crimson Energy/CE 1000
Type: Enclosed
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: NA
Waste Gas Heat Content:
Constant Pilot Light: Q Yes ❑ No Pilot Burner Rating:
2864
0.02
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 50 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
COLOR 0C
4I
Permit Number:
AIRS ID Number: /
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Combustor
95
NOx
CO
RAPS
Combustor
95
Other:
From what year is the following reported actual annual emissions data?
2017
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/ ear
y )
Controlled
Emissions7
(Tons/year)(Tons/year)
(Tons/ ear
Uncontrolled
Emissions
Controlled
Emissions
(Tons/ ear
y )
VOC
10.97
lb/bbl
S e e
kr��S
453.58
22.68
NOx
0.068
Ib/MMBtu
AP -42
0.16
0.71
CO
0.31
Ib/MMBtu
AP -42
3.23
3.23
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
g
Uncontrolled
Emissions
Pounds/ ear
(Pounds/year) )
Controlled
Emissions7
(Pounds/year)
Benzene
71432
0.0598
lb/bbl
E&P Tanks
4942.6
247.1
Toluene
108883
0.0183
lb/bbl
E&P Tanks
1512.5
75.6
Ethylbenzene
100414
.00081
lb/bbl
E&P Tanks
Xylene
1330207
.0054
lb/bbl
E&P Tanks
446.7
22.3
n -Hexane
110543
0.328
lb/bbl
E&P Tanks
27107.2
1355.4
2,2,4-540841
Trimethylpentane
0.0151
lb/bbl
E&P Tanks
1244.6
62.2
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach crude oil laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
ccLcRurc
51
Permit Number: AIRS ID Number:
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.
8.-30 -/ 7
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:
Draft permit prior to issuance
�✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $152.90 and the General Permit For more information or assistance call:
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-315Q
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https: //www.colorado.gov/cdphe/apcd
COL 9R:0O
614±_
Natural Gas Venting APEN - Form APCD-211
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re -submittal.
This APEN is to be used for Natural Gas Venting only. Natural Gas Venting includes emissions from gas/liquid
separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does
not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN
(Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms can be found on the Air Pollution Control Division (APCD) website at:
www.colorado.00v/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 -1- t/v E v 7- 9 ° AIRS ID Number: 12 3 / dt AI,
Company equipment Identification: SEPARATOR
009
',Our
Section 1 - Administrative Information
Company Name': Longs Peak Resources, LLC
Site Name: Pismo 35-2-2-2CH
Site Location: NWNE Sec. 35, T12N, R66W
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
Northglenn, CO 80234
E -Mail Address': dclarkson@vrtxep.com
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: David Clarkson
Phone Number: 303-997-5558
'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.
368540
CCLORt00
Permit Number: AIRS ID Number:
S
Section 2- Requested Action
2 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 it Notes:
' 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:
no gathering pipeline in place
Flaring of separator gas for wildcat well,
For existing sources, operation began on:
For new or reconstructed sources, the projected
start-up date is:
05 / 16 / 2017
/ /
❑ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day
Will this equipment be operated in any NAAQS nonattainment
area
Is this equipment located at a stationary source that is
considered a Major Source of (HAP) Emissions
days/week weeks/year
❑ Yes
❑ Yes
2 1 b
❑✓ No
O No
CCLOR..DC
Permit Number: AIRS ID Number: / /
Section 4 - Process Equipment Information
E Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model:
❑ Compressor Rod Packing
Make: Model:
❑ Blowdown Events
# of Events/year:
❑ Other
Description:
Serial #: Capacity: Gal/min
# of Pistons: Leak Rate: Scf/hr/pist
Volume per event: MMscf/event
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a Gas/Liquid Separator you must use Natural
Gas Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? 0 Yes
Natural Gas Venting
Process Parameters4:
Liquid Throughput
Process Parameters4:
❑ No
Maximum Vent
Rate:
1200O
SCF/hr
Vent Gas
Heating Value:
1476.4
BTU/SCF
Requested:
80.1
MMSCF/year
Actual:
MMSCF/year
-OR-
Requested:
Bbl/yr
Actual:
Bbl/yr
4 Requested values will become permit limitations. Requested limit(s) should consider future process growth
Process Properties:
Molecular Weight:
VOC (mole %)
21.2617
VOC (Weight %)
Benzene (mole %)
0.0379
Benzene (Weight %)
Toluene (mole %)
0.0751
Toluene (Weight %)
Ethylbenzene (mole %)
0.0166
Ethylbenzene (Weight %)
Xylene (mote %)
0.0322
Xylene (Weight %)
n -Hexane (mole %)
0.3349
n -Hexane (Weight %)
2,2,4-Trimethyipentane
(mole %)
0.0140
2,2,4 Trimethylpentane
(Weight %)
Additional Required Information:
❑ Attach a representative gas analysis (including BTEX a n -Hexane, temperature, and pressure)
Attach a representative pressurized extended liquids analysis (including BTEX Et n -Hexane, temperature, and
pressure)
3 b
Permit Number:
AIRS ID Number:
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.96935/-104.74135
Operator
Stack ID No.
Discharge Height
Above Ground Level
Temp.
(.F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
(Feet)
COMBUSTOR
35
1000
variable
variable
Indicate the direction of the stack outlet: (check one)
✓❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
E Circular Interior stack diameter (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
96
Section 6 - Control Device Information
❑ VRU:
Pollutants Controlled:
Size:
Make/Model:
Requested Control Efficiency
VRU Downtime or Bypassed
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs, H2S
Rating: 1 000 mscfd MMBtu/hr
Type: Enclosed Make/Model: Crimson Energy, CE 1000
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency
Minimum Temperature:
98
NA Waste Gas Heat Content 1476.4 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating
0.02 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency
Requested
0/0
CC LCC CDC
41
Permit Number:
AIRS ID Number:
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? Q✓ Yes ❑ No
If yes, please describe the control equipment AND state the overall control efficiency (% reduction):
Pollutant
Control Equipment Description
Overall Requested Control
Efficiency
(% reduction in emissions)
PM
SO,
NO„
VOC
Combustor
95
CO
HAPs
Combustor
95
Other:
H2S conversion to SO2 - Combustor
100% Conversion
From what year is the following reported actual annual emissions data?
2017
Use the following table to report the criteria pollutant emissions from source:
(Use the data reported in Sections 4 and 6 to calculate these emissions.)
Pollutant
Uncontrolled
Emission
Factor
Emission
Factor
Units
Emission
Factor
Source
(AP -42,
Mfg. etc)
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
(Tons/year)
Controlled6
(Tons/year)
Uncontrolled
(Tons/year)
Controlled
(Tons/year)
PM
SOX
1.65E-3
Ib/MMBtu
Mass Balance
0.03
0.03
NO,
0.068
Ib/MMBtu
AP -42
4.02
4.02
VOC
23.07
Ib/MMBtu
Mass Balance
1267.18
63.36
CO
0.31
Ib/MMBtu
AP -42
18.33
18.33
Benzene
78.11
Ib/MMscf
Mass Balance
3.13
0.16
Toluene
182.58
Ib/MMscf
Mass Balance
7.31
0.37
Ethylbenzene
46.50
Ib/MMscf
Mass Balance
1.86
0.09
Xylenes
90.20
Ib/MMscf
Mass Balance
3.61
0.18
n -Hexane
761.52
Ib/MMscf
Mass Balance
30.50
1.53
2,2,4-
Trimethylpentahe
42.19
lb/MMscf
Mass Balance
1.69
0.08
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
5 I C3
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.
g•3v•/
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:
Q Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
Send this form along with $152.90 to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and
Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
6 I dr' cr,ioer.oc
Produced Water Storage Tank(s)
APEN Form APCD-207
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 produced water associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, condensate 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:
AIRS ID Number: 1 2,3 /IF91/ 005
err' ..i..1
Section 1 - Administrative Information
Company Name': Longs Peak Resources, LLC
Site Name: Pismo 35-2-2-2CH
Site Location: NWNE Sec. 35, T12N, R66W
Mailing Address:
(Include Zip Code) 10701 Melody Dr., Suite 515
Northglenn, CO 80234
Site Location
County: Weld
NAICS or SIC Code: 1311
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.
370103
1 AV
COLORADO
Department of P* bUc
Atr EANmnmem
Permit Number:
AIRS ID Number:
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP05 ❑ 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 -
El APEN submittal for permit exempt/grandfathered source
Additional Info Et Notes: Permit Exempt - Reg. 3, Part B.II.E.3.uu, however
requesting federally enforceable limits
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:
2-400 bbl produced water tanks
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7
05/16/2017
days/week
52
weeks/year
✓❑ Exploration a Production (EEP) site ❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
■
Yes
ID
No
Are Flash Emissions anticipated from these storage tanks?
12
Yes
■
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
No
•
p
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
GI
Yes
■
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
•
p
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
O
■
2I AV
COLORADO
vYro�unmu
Permit Number:
AIRS ID Number: /
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl /year)
Produced Water Throughput:
From what year is the actual annual amount?
Tank design:
❑✓ Fixed roof
2017
❑ Internal floating roof
Requested Annual Permit Limit4
(bbl/year)
224081
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
PROD WTR
2
800
3/17
5/17
Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites On y)
API Number
Name of Well
Newly Reported Well
05 - 123- 407a
Pismo 35-2-2-2CH
o
CI
■
■
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.96935/-104.74135
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)
2 Upward
El Horizontal
El Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches): 96
❑ Square/rectangle
❑ Other (describe):
Interior stack width (inches):
Interior stack depth (inches):
3I AY
COLORADO
Ocpuunent el P.3Uc
HtAOt Fe Envirannu d
Permit Number: AIRS ID Number: / /
hThr
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (\'RU):
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
0/0
❑ Combustion
Device:
Pollutants Controlled: VOC, HAPs
Rating: 1000 mscfd
Type: Enclosed
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: NA
MMBtu/hr
Make/Model: Crimson Energy/CE 1000
95 %
98
%
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
2864
0.02
Btu/scf
MMBtu/hr
El Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
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)? 50
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
:ion 2Q 7 4 I AV
COLORADO
Health bEnhgnnmenu
Permit Number:
AIRS ID Number:
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):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Combustor
95
NOx
CO
HAPs
Combustor
95
Other:
From what year is the following reported actual annual emissions data? 201 7
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source -
(AP -42,
Mfg. etc) )
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions?
(Tons/year)
Uncontrolled
Emissions ;
(Tans/year)
Controlled
Emissions
(Tons/year)
;IOC
0.262
lb/bbl
State
05
1.47
NOx
2.4.-35
//
CO
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service CAS
(CAS)
Number
Emission Factor6
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
4
Uncontrolled
Emissions
(Pounds/year) ear
( y )
Controlled
Emissions7
(Pounds/year).'.
Benzene
71432
0.007
lb/bbl
State
1568.6
78.4
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.022
lb/bbl
State
4929.8
246.5
2,2,4-
Trimethylpentane
540841
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 Attach produced water laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific
emissions factors according to the guidance in PS Memo 14-03.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
grIrtttn
err) r
7J1- 51 AY
Depsnment of Public
COLORADO
Permit Number: AIRS ID Number: / /
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 GP05 or GP08, I further certify that this source is
and will be operated in full compliance with each condition of the applicable General Permit.
/D -t5•/7
Signature of Legally Authorized Person (not a vendor or consultant)
David Clarkson
COO
Date
Name (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 $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
Make check payable to: https://www.colorado.gov/cdphe/apcd
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
6 I AF9F x===1,
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