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HomeMy WebLinkAbout20200622.tiffCOLORADO Department of Public Health b Environment Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 September 30, 2020 Dear Sir or Madam: RECEIVED OCT 0 2 2020 WELD COUNTY COMMISSIONERS On October 1, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - McNear 10-9 Pad. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director Pvbl:c ReviatJ 1O/14 /.i.D <<: Pn em), HL(Ds)p.417M/ER/CH/cw), O6(3m) iolog/20 CDPHE Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - McNear 10-9 Pad - Weld County Notice Period Begins: October 1, 2020 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: PDC Energy, Inc. Facility: McNear 10-9 Pad Exploration Et Production Well Pad Facility. NWSE SEC 9 T6N R66W Weld County The proposed project or activity is as follows: Applicant proposes permitting of one condensate tank battery and one loadout operation at an OEtG production facility which was newly constructed in the NAA in Weld County in August, 2019. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0810 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. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 AG4ti Ntei. COLORADO Department of Public Health Et Environment COLORADO Air Pollution Control Division I Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0810 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: McNear 10-9 Pad Plant AIRS ID: 123/A07B Physical Location: NWSE SEC 9 T6N R66W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TNK 1-6 001 Six (6) 400 barrel fixed roof storage vessels used to store condensate 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. 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 must 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/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must 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 Page 1 of 14 COLORADO Air Pollution Control Division Department of Public Health 6 Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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.) I. F.4. ) 3. Upon issuance of this permit, the operator must install equipment necessary to monitor control device pilot light status and auto -igniter status as described in this permit. 4. The operator must 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 must 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 must 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 NOX VOC CO TNK 1-6 001 --- 2.1 23.9 9.8 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 must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to alt permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must 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 owner or operator must use the emission factors and calculation methods found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility potential emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, Page 2 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC 9. The emission points in the table below must 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 TNK 1-6 001 Emissions are routed to a bank of four (4) Enclosed Flares. Make: IES, Model: 96", SNs: 96-01-118, 96- 01-119, 96-01-120, 96-03-0130 VOC and HAP PROCESS LIMITATIONS AND RECORDS 10. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TNK 1-6 001 Condensate throughput 1,180,848 barrels The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 11. On a minimum of an hourly basis, the owner or operator shall monitor the control devices for the presence of a pilot light and an operational auto -igniter on each device. These monitoring records shall be used to calculate control device downtime. During periods without the presence of a pilot light and/or an operational auto -igniter, the flow volume from emissions source(s) shall be assigned a 0% control efficiency. These monitoring records must be maintained for a period of five (5) years, and a summary of monthly pilot light downtime and vapor flow during pilot light downtime shall be provided to the division upon request. Page 3 of 14 at, COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado STATE AND FEDERAL REGULATORY REQUIREMENTS 12. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III. E.) (State only enforceable) 13. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 14. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 15. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.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 II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7, Part D, Section II.B.2.d. 16. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must 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 March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.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. 17. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, Page 4 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING £t MAINTENANCE REQUIREMENTS 19. Upon startup of these points, the owner or operator must 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 20. The owner or operator must complete site specific sampling including a compositional analysis of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for emission factor development, a sales oil analysis to determine RVP and API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants using Division approved methods. Results of site -specific sampling and analysis must be submitted to the Division as part of the self -certification and used to demonstrate compliance with the emissions factors chosen for this emissions point. 21. The owner or operator must 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, Part D, Sections I.C, II.B.2. and II.A.23) 22. The owner or operator must conduct an initial source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the VOC emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (M1) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA or other division approved methods; and •. mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. Page 5 of 14 COLORADO Air Pollution Control Division �l�' �' , Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must include testing under all operating scenarios of the control device. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Results of the initial compliance tests must be submitted to the Division as part of the self - certification. Actual emissions calculations must be completed in accordance with the "Notes to Permit Holder" section of this permit. If the results of the initial compliance test do not demonstrate compliance with the emissions limits contained within this permit or do not demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC) for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Periodic Testing Requirements 23. On an annual basis, the owner or operator must complete a site specific analysis ("Analysis"), including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to the equipment covered in this permit. Testing must be in accordance with the guidance contained in PS Memo 05-01. Results of the Analysis must be used to demonstrate that the emissions factor established through the Analysis is less than or equal to the emissions factor submitted with the permit application and established herein in the "Notes to Permit Holder" for this emissions point. If any site specific emissions factor developed through this Analysis is greater than the emissions factors submitted with the permit application and established in the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. 24. On an annual basis, the owner or operator must conduct a source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the VOC emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (MO using EPA or other division approved methods; and • mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Page 6 of 14 COLORADO Air Pollution Control Division Department cf Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Additionally, the following parameters may be required to be measured during the test: • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(M;-Mo)/M; The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must include testing under all operating scenarios of the control device. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Actual emissions calculations must be completed in accordance with the "Notes to Permit Holder" section of this permit. If the results of the periodic compliance test do not demonstrate compliance with the emissions limits contained within this permit or do not demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC) for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. ALTERNATIVE OPERATING SCENARIOS 25. The control device may be replaced with a like -kind control device in accordance with the requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this permit or obtaining a new construction permit. A like -kind control device shall be the same make and model as authorized in this permit. All control device replacements installed and operated as authorized by this permit must comply with all terms and conditions of this construction permit. The owner or operator shall maintain a log on -site or at a local field office to record the start and stop dates of any control device replacement, the manufacturer, model number and serial number of the replacement control device. 26. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and serial number of the replacement control device must be filed with the Division within 14 calendar days of commencing operation of a replacement control device under the Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate APEN filing fee and a cover letter explaining that the owner or operator is exercising an Alternative Operating Scenario and has replaced the control device. Page 7 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 27. Within one hundred and eighty days (180) of startup of the replacement control device in accordance with the Alternate Operating Scenario provision, the owner or operator must conduct an initial source compliance test to measure the mass emission rates of the pollutants listed below, demonstrate compliance with the emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC). During the test, the owner or operator must measure: • mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other division approved methods; • mass emission rates of VOC at the outlet of the control device (M0) using EPA or other division approved methods; and • mass emission rates of NOx and CO at the outlet of the control device using EPA or other division approved methods. Additionally, the following parameters may be required to be measured during the test: • combustion chamber temperature; • gas flow rate; • supplemental fuel flow rate; • gas heat content; and • gas composition. The destruction efficiency (DE) for VOC must be calculated using the following equation: DE (%) = 100*(Mi-Mo)/M1 The test protocol, test, and test report must be in accordance with the requirements of the Air Pollution Control Division Compliance Test Manual. The test protocol must include testing under all operating scenarios of the control device. The test protocol must be submitted to the Division for review and approval at least thirty (30) days prior to testing. No compliance test will be conducted without prior approval from the Division. Within thirty (30) days following completion of the test(s), a compliance test report must be submitted to the Division for review. Additional time may be granted upon written request. Any compliance test conducted to demonstrate compliance with a monthly or annual emission limitation shall have the results projected up to the monthly or annual averaging time by multiplying the test results by the Process Limit(s) for that averaging time as indicated in the Process Limitations and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3) Actual emissions calculations must be completed in accordance with the "Notes to Permit Holder" section of this permit. If the results of the initial compliance test do not demonstrate compliance with the emissions limits contained within this permit or do not demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC) for each operating scenario, the owner or operator must submit to the Division within 60 days, or in a timeframe as agreed to by the Division, a request for permit modification to address these inaccuracies. Page 8 of 14 ktty COLORADO Air Pollution Control Division Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 28. A revised Air Pollutant Emission Notice (APEN) must 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,t 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. 29. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 30. 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. 31. 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 Page 9 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 32. 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. 33. 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. 34. 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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. 35. 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. 36. 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: DRAFT Ben Fischbach Permit Engineer Page 10 of 14 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. New Synthetic Minor Facility Page 11 of 14 COLORADO toe Air Pollution Control Division I Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions - (Ib/yr) 001 Benzene 71432 6,129 123 Toluene 108883 4,853 97 Ethylbenzene 100414 345 7 Xylenes 1330207 1,571 31 n -Hexane 110543 40,790 816 2,2,4- Trimethylpentane 540841 148 3 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 0.0036 0.0036 AP 42 CO 0.0165 0.0165 VOC 2.02 0.0404 ProMax 71432 Benzene 5.19 * 10-3 1.04 * 10-4 Page 12 of 14 COLORADO Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 108883 Toluene 4.11 * 10-3 8.22 * 10-5 100414 Ethylbenzene 2.92 * 10-4 5.84 * 10-6 1330207 Xylene 1.33 * 10-3 2.66 * 10"5 110543 n -Hexane 3.45 * 10-2 6.91 * 10"4 540841 2'2'4-1.25 Trimethylpentane * 10-4 2.51 * 10-6 Note: The controlled emissions factors for this point are based on a control efficiency of 98%. NOx and CO emission factors are based on a gas heat content of 2,553 Btu/scf. Actual controlled emissions shall be calculated using the following method: Monthly Actual Emissions = [(Vtotat — VPLX) X EF x (100% — CE)] + [VPLX x EF] where: Vtorar = Total volume of condensate throughput (bbl) VPLX = Total volume of condensate throughput while pilot light was not lit or auto -igniter was not operational (bbl) EF ' = Most recent approved uncontrolled emission factor (lb/bbl) CE = 98% 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 must 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, CO, NOx, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx MACT HH 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: Page 13 of 14 COLORADO Air Pollution Control Division (Department ct Public Wealth & Env ronment Dedicated to protecting and improving the health and environment of the people of Colorado http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 14 of 14 C6oraolo Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package 8: 414411 Received Date: 8/7/2019 Review Start Date: 9/19/2019 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section I Township Range County AIRS ID: 123 NWSE 9 6N 66 Plant AIRS ID: A07R Facility Name: McNear 10-9 Pad Physical Address/Location: . _ ; Y Range 664.1 County: Weld County Type of Facility: Exploration&Production Well Pad What industry segment?Oil&Natural Gas Production&Prodess ng { ,; ` . Is this facility located in a NAAQS non-atta me t area? Yes ' If yes,for what pollutant? IA Carbon Monox de(CO) ❑Particulate Matter(PM) Q Ozone(NOx&SCC) Section 02-Emissions Units In Permit Application Emissions Self Cert AIRs Point it Emissions Source Type Equipment Name Permit ti Issuance n Action Engineering Remarks Control? Required? Permit Initial 001 Condensate Tank TNK 1-6 Yes 19WE0810 1 Yes Issuance Analysis pages hidden in this workbook-see PA for 19W E0811.CP1 for analysts of point Permit Initial 002, 002 --:Liquid Loading LOAD-1 Yes 19WE0811 1 Yes Issuance Section 03-Description of Project Applicant proposes permitting of one condensate tank battery and one loadoutoperation at an O&G production facility which was newly constructed in the NAA in Weld County in August,2019. Facility/Project both Synthetic minor for VOC-project.requires Public Notice period. Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? -_Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ✓ ' ,I Title V Operating Permits(OP) 1 ./ Li LJ Non-Attainment New Source Review(NANSR) ./ J Is this stationary source a major source? No If yes,explain what programs and which pollutants herr SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention Operating of acing t Deterioration(PSD) n I I Title V Operating Permits(OP) Ir; Non-Attainment New Source Review(NANSR) Coil{'("r1SaC? S≥vt≥" T= la lt(5� Ernissions invent )l y 001 Condensate Tank Facility AIRs ID: 123 County 1078 001 Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Six (6)- 400 bbl Condensate Storage Tanks. Description: Emission Control Device Enclosed Flare. Description: - Requested Overall VOC & HAP Control Efficiency %: Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = 984,022 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = Requested Monthly Throughput = 984,022 Barrels (bbl) per year 1,180,848 Barrels (bbl) per year 10329) Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput 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 routed to combustion device = Section 04- Emissions Factors & Methodologies 1,180,848 Barrels (bbl) per year 2553 Btu/scf 20.8845 scf/bbl Will this storage tank emit flash emissions? Heat Content based on weighted average of W &B and Flash streams from Promae (weightedbased on relative flow rates). •*: MM BTU per year 5510..' MM BTU per year it MMBTU per year Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 2.02 .• O404 Site Specific E.F..(,c) dec flash) Benzene 5.19E-03 _..F 04 Site Specific E.F. ): , odes flash) Toluene 4.11E-03 3.22E-03 Site Specific E.F. (o -dudes flash) Ethylbenzene 2.92E-04 5 31E O£ Site Specific E.F. (includes flash) Xylene 1.33E-03 __:._,.5 Site Specific E.c ):o€lodes flash) n -Hexane 3.45E-02 ..-_1.=-04 Site Specific EC. (includes flash) 224TMP 1.25E-04 .,.E-05 Site Specific E.F,(iodudes flash) Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) (Ib/bbi) Emission Factor Source (waste heat combusted) (Condensate Throughput) PM10 "3.0000 PM2.5 5 0000 NOx 0.0680 0.0036 AP -42 Chapter.13,51pdustrial Flares (NOx) CO 0.3100 0.0165 AP -42 Chaptel ,SJOdustrial Flares (CO) Section OS - Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) VOC 1192.48 993.12 -- _ 119? c PM10 00 21 0.0 60 ._.l PM2.5 :1 0 �-_. 0.0 - NOx CO 2.14 1.78 1.75 2.1 .., 3.76 9 13 8,13 9 8 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 5129 0137 102 5129 Toluene 1013 4014 81 -1003 . Ethylbenzene 341 287 3 345 Xylene 1571 1309 26 ST: 11 n -Hexane 30790 33991 680 1;790 Sic 224 TMP 148 5233 2 118 1 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B ,,,,broe requires a permit Regulation 7, Section XII.C, D, E, F _s., ge tank rs subject to Regulation 7. Sectoo X3 CE Regulation 7, Section XII.G, C Storage Tank Is not taller( zv Regulation 7 ',echo:: /1 O Regulation 7, Section XVll-B, C.1, C.3 Stcrag: tankss subject to Regulaton 7, Section Xs P. 8 7.1 S._. Regulation 7, Section XVII.C.2 Storage tonic is subject to R, g =rate€ - Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not.005:ect to NSPS PE Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not ,oble.t to 0515 OW 1110 Regulation 8, Part E, MAT Subpart HH Storage Tank i., not ...jets to MOM" laH I (See regulatory applicability worksheet for detailed analysis) 2 of 6 K:\PA\2019\19W E0810.CP1 Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain en "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95%for a flare er combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the_ combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Site -specific emission factors based on a Promax sample which models the condensate tank only. Promax model was specified based on; an extended natural gas liquid analysis which was performed on the pressurized liquid winch is transported into the condensate tanks at this facility. Extended natural gas liquid analysis was performed/provided by Alliance Source Testing, with a sample date of 7/19/19 and an analysis date of 7/22/19. The liquid sample was collected from a 'Gas Buster" at the McNear 10-9 facility, at a pressure of 18.9 psig (ambient = 12.3 psia), and a temperature of lotF. Promax model which was originally submitted with this aopacation specified a separator pressure which was slightly higher than that reported on the sample analysis. I discussed this with operator, and. discrepancy camefrom fact that, while operator specified a condensate tank pressure of 12.12 psia (local ambient), they left the overall "Protect" ambient pressure at 14.7 psia (sea level). Operator ran a new version of the Promax model in which the overall ambient pressure was set to 12.12 psia, and the results showed that emissions did not change from initial model (this result likely has to do with the sample analysis showing that the sample ten slightly outside of the phase envelope- I compared a similarly rills -specified model from a different project, and found that correcting the pressure (from a sample which was collected on the others de of the phase envelope border) estimated less emissions (i.e the originally submitted model was more conservative), but was still negligible.). Given the fact that specifying the pressures in the original models yielded more conservative results, will accept those emission factors and permit based on those values. AIRS Point tt 001 Process X SCC Code 01 st Section 09 - Inventory 5CC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.09 0 lb/1,000 gallons condensate throughput VOC 48.1 98 lb/1,000 gallons condensate throughput CO 0.39 0 lb/1,000 gallons condensate throughput Benzene 0.12 98 lb/1,000 gallons condensate throughput Toluene 0.10 98 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 98 Ib/1,000 gallons condensate throughput Xylene 0.03 98 lb/1,000 gallons condensate throughput n -Hexane 0.82 98 lb/1,000 gallons condensate throughput 224 TMP 0.00 98 lb/1,000 gallons condensate throughput 3 of 6 K:\PA\2019\19WE0810.CP1 Condensate Tank Regulatory Analysis Worksheet Colorado Re -Motion 3 Parts A and B -OPEN and Permit Requirements ,:, sa see eveniement neen ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section lt.D.1.a)? 2. 8 the construction date (service date) prtorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Detintions 1.12 and1.14 and Section 2 for additional guidance en grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOT greaterthan 10 TPY or CO emissions greater than 10 TM( (Regulation 3, Part B, Section 11.0.31? NON -ATTAINMENT L Are uncontrolled emissions from any criteria pollutants from this lndivldualsource greaterthan l TPY (Regulation 3, Part A, Section Il.D.l.a)? 2. la'd'e construction date (service date) prior to 12/30/2062 and not modified after l2/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Aretotal facility uncontrolled VOC emissions greaterthan 2 TPY, hoe greater than 5 TPV or CO emissions seater than 10 TPY (Regulation 3,153 3; Section 11.0.2)? IVic..`r 1 . n a .r -.t Colorado Regulation 7, Section XII.C-F 1. Isthiestorage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? As , -C- Section 011.0.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section %R,C.2 —Emission Estimation Procedures Section %R.0 —Emissions Control Requirements Section XR.E— Monitoring Section OR.F — Recordkeeping and Reporting Colorado Regulation 7, Section %the 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. [..this storage tank exhibit"Flash" (e.g. storing non -stabilized liquids)emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC Yom'-' W Section X11.0.2- Emissions Control Requirements Section XII.Ci —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storagetank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storagetank? 4. Are uncontrolled actual emissions' of this storage tank equal to orgreaterthan 6 tons per year VOC? E Section %VII.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? Section %Vll.42 - Capture and Monitoring for -Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the Individual storage vessel capacity greaterthan or equal to 75 cubic meters (m') [5472 BBts]? 2. Does the storage vessel meet thefollowing exemption in bo.111h(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 NO r10,000 BBL] used forpetroleuni or condensatestored,processed, or treated prior to custodytransfer as defined in 6o.111b? 3. Was this condensate storagetank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) afterluly 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.1116? 5. Does the storage vessel stare a"volatile organic liquid (VOL)"' as defined in 60.1116? G. Does the storage vessel meet any one of the following additional exemptions: a. Is the. storagevessel a pressure vessel designedto operate in excess of 204.9 kPa [^29.7 pail and without emissions to the atmosphere (6o.11ob(d)(2))?; o I. The design capacty is greater than or equalto 151 m' [`950 BBL] and stores a liquid with a maximum truevapor pressure' less than 3.5 kPa (6o.11ob(6))?r or p The design capacity is greater than or equal to 75 he !'"472 Boy but less than 151 ma[5050 Bill and stores a liquid with a maximum tnsevaeor pressure' less than 15.0 kPa(6o.11ob(b)l? Interns Te=e°s eossokirms• 3uP5rie Subpart A, General Provisions §60.111b - Emissions Control Standards for VOC §60.113b -Testing and Procedures 460,1156- Reporting and Recordkeeping Requirements §60.Si66 - Monitoring of Operations 40 045, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1, Is this condensate storage vessel located at a facility in the onshore oil -and natural gas production segment, natural gas processing segment or natural gastransmusion and storage segment ofthe induery? 2. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vesselgreeterthan or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? S. Isthestorage vessel subject to and controlled in accordance with re mrements for stow evessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HH? Yet. WAN Q'k Ong Subpart A, General Provisions per§60.5425 Table 3 §66.5395- Emissions Control Standards -I. -00G 460 5413 -resting and Procedures §60.5395(8) -Notification, Reporting and Recordkeeping Requirements §60.50.6(c)- cand Closed Vent system Monitoring Requirements 460.5417 - Control Device Monitoring Requirements [Nate: If a storage vessel is previously determined to be subjectta NIPS 0000 due to emissions above 6 tons per year VOCan the applicability determination date, it should remain subject to NSPS O000 per 60.6365(e)(2) even If potential Von emissions drop below 6 tons par lead 40 CFR, Part 63, Subpart MACT NH, Oil and Gas Production Fealties 1. Is the storagetank located at an oil and natural gas production facility that meets either of the following criteria: e. A tacilitythat processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. Afacility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delNered to a final end useri (63.76o(a)(3))? 2. Is thetank located ate facility that is major' for HAPs? 3. Goesthetank meet the definition of, "storagev sel" in 63.761? 4. Does thetank meet the definition of"storage vessel with the potential for flash emissions"' per63.761? 5. Is the tank subject to control requirements under 46 CFR Part 60, Subpart Kb or Sub art 0000? 13,3Joyee hnekns Subpart A, General provisions per §63.764 (a) Table 2 063.766 - Emissions Control Standards §63.773 -Monitoring 465.774- Recordkeeping 463.775 -Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review PACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particulars/Nation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Quality Control Commission regulations, the language of the statute of regulation will control. The use of non -mandatory language such as "recommend," "may," "should,"and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and "required' are intended to describe. controlling requirements under the terns of the Clean Air Act and Air Quality Control Commission regulations, but this document dues not establish legally binding requirements in and ofitself Source nee Go to next Source Req Continue Continue-' Source is st Continue-" Storage Tar Source is st Continue Go to the n Iota then Source is st eTar continue -) Storage Tar her ICantinue- torage Tar COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID A07B Facility Name McNear 10-9 History File Edit Date 09 September 2020 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) 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 Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0810 Condensate Tanks (6-400 bbl) 2.1 1192.5 9.8 26.9 2.1 23.9 9.8 0.5 New 002 19WE0811 Condensate Loadout 0.0 29.8 0.2 0.6 0.0 1.5 0.2 0.0 New 003 GP08 Produced Water Tanks (2-400 bbl) 0.1 17.2 0.6 1.2 0.1 5.9 0.6 0.1 New 004 GP02 RICE 1150 Hp 0.1 0.1 5.6 9.8 27.6 2.6 0.1 0.1 5.6 7.8 16.7 1.3 No change 005 GP02 RICE 550 Hp 0.1 0.1 39.5 3.8 66.4 0.5 0.1 0.1 2.7 3.8 8.0 0.5 No change 006 GP02 RICE 550 Hp 0.1 0.1 39.5 3.8 66.4 0.5 0.1 0.1 2.7 3.8 8.0 0.5 No change 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.3 0.3 0.0 0.0 86.8 1256.9 0.0 171.0 32.5 0.3 0.3 0.0 0.0 13.2 46.7 0.0 43.3 3.0 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor B, T, X, HCHO & Total HH: Syn Minor + affected Area 7777• Sun Miner Permitted Facility Total 0.2 0.2 0.0 0.0 10.5 42.9 0.0 35.3 2.4 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.2 0.2 0.0 0.0 10.5 42.9 0.0 35.3 Pubcom & modeling (not) required based on (A change in emissions) Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Pe mitted VOC emiss ons (point and fugitive) 46.7 Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 42,9 Page 5 of 6 Printed 9/9/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs 123 AO7B McNear 10-9 Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP TOTAL (tpy) 001 19WE0810 Condensate Tanks (6-400 bbl) 6129 4853 345 1571 40790 148 26.9 002 19WE0811 Condensate Loadout 100 84 6 28 1000 4 0.6 003 GP08 Produced Water Tanks (2-400 bbl) 929 725 56 192 592 0 1.2 004 GP02 RICE 1150 Hp 3773 720 443 38 215 2.6 005 GP02 RICE 550 Hp 732 100 94 56 109 0.5 006 GP02 RICE 550 Hp 732 100 94 56 109 0.5 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 2.6 0.5 0.3 3.7 2.8 0.2 0.9 21.2 0.2 0.1 32.5 Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP TOTAL (tpy) 001 19WE0810 Condensate Tanks (6-400 bbl) 123 97 7 31 816 3 0.5 002 19WE0811 Condensate Loadout 5 4 0 1 50 0 0,0 003 GP08 Produced Water Tanks (2-400 bbl) 46 36 3 10 30 0 0.1 004 GP02 RICE 1150 Hp 1110 720 443 38 215 1.3 005 GP02 RICE 550 Hp 732 100 94 56 109 0.5 006 GP02 RICE 550 Hp 732 100 94 56 109 0.5 0,0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 1.3 0.5 0.3 0.2 0.1 0.0 0.0 0.4 0,2 0.0 3.0 6 19WE0810.CP1 9/9/2020 ,,,,,,,,.,�.��•�,�- COLORADO Nt Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0811 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: McNear 10-9 Pad Plant AIRS ID: 123/A07B Physical Location: NWSE SEC 9 T6N R66W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control ID Point Equipment Description Description LOAD-1 002 Truck loadout of condensate by Enclosed Flare submerged fill 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. 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 must 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/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must 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 Page 1 of 11 COLORADO Air Pollution Control Division Department at Pubttc Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III. F.4. ) 3. The operator must 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 4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4) Annual Limits: Equipment ID AIRS Point Tons per Year Emission Type pM2.5 NOX VOC CO LOAD -1 002 --- --- 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 must not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 6. The owner or operator must track emissions from all insignificant activities at the facility on an annual basis to demonstrate compliance with the facility emission limitations as indicated below. An inventory of each insignificant activity and associated emission calculations must be made available to the Division for inspection upon request. For the purposes of this condition, insignificant activities are defined as any activity or equipment, which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3, Part C. II.E.) E. ) Page 2 of 11 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Total potential emissions from the facility, including all permitted emissions and potential to emit from all insignificant activities, must be less than: • 50 tons per year of VOC. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment ID AIRS Point Control Device Pollutants Controlled LOAD -1 002 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4) Process/Consumption Limits Equipment ID AIRS Point Process Parameter Annual Limit LOAD -1 002 Condensate Loaded 118,085 barrels The owner or operator must calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits must 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 must 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. 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. (Regulation Number 1, Section II.A.1. It 4.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) Page 3 of 11 COLORADO Air Pollution Control Division Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado 11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control equipment. Compliance with Section II.C.5. must be achieved in accordance with the following schedule: (Regulation Number 7, Part D, Section II.C.5.a.) • Facilities constructed or modified on or after May 1, 2020, must be in compliance by commencement of operation. • Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021. • Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to 5,000 barrels per year on a rolling 12 -month basis must control emissions from loadout upon exceeding the loadout threshold. 12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7, Part D, Section II.C.5.a.(ii)) 13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)): • Install and operate the vapor collection and return equipment to collect vapors during the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles and to route the vapors to the storage tank or air pollution control equipment. • Include devices to prevent the release of vapor from vapor recovery hoses not in use. • Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to transport vehicles unless the vapor collection and return system is in use. • Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. • The owner or operator must inspect onsite loading equipment to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loadout. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring. 14. The owner or operator must perform the following observations and training (Regulation Number 7, Part D, Section II.C.5.a.(iv)): • The owner or operator must observe loadout to confirm that all storage tanks operate without venting when loadout operations are active. These inspections must occur at least monthly, unless loadout occurs less frequently, then as often as loadout is occurring, • If observation of loadout is not feasible, the owner or operator must document the annual loadout frequency and the reason why observation is not feasible and inspect the facility within 24 hours after loadout to confirm that all storage tank thief hatches (or other access point to the tank) are closed and latched. Page 4 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado • The owner or operator must install signage at or near the loadout control system that indicates which loadout control method(s) is used and the appropriate and necessary operating procedures for that system. • The owner or operator must develop and implement an annual training program for employees and/or third parties conducting loadout activities subject to Section II.C.5. that includes, at a minimum, operating procedures for each type of loadout control system. 15. The owner or operator must retain the records required by Regulation Number 7, Part D, Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon request. • Records of the annual facility hydrocarbon liquids loadout to transport vehicles throughput. Inspections, including a description of any problems found and their resolution, required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log. Records of the infeasibility of observation of loadout. Records of the frequency of loadout. Records of the annual training program, including the date and names of persons trained. 16. Air pollution control equipment used to comply with this Section II.C.5. must comply with Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi)) 17. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division -approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 18. Upon startup of these points, the owner or operator must 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 OEtM 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 Page 5 of 11 COLORADO Air Pollution Control Division Department of Public Health El Environment Dedicated to protecting and improving the health and environment of the people of Colorado 19. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 20. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section 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,t per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 22. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B). Page 6 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado GENERAL TERMS AND CONDITIONS 23. 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. 24. 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. 25. 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. 26. 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. 27. 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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. 28. 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. Page 7 of 11 COLORADO Air Pollution Control Division Department of Public Health fr Environment Dedicated to protecting and improving the health and environment of the people of Colorado 29. 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: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. New Synthetic Minor Facility Page 8 of 11 'COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must 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. 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) 001 Benzene 71432 100 5 Toluene 108883 84 4 Ethylbenzene 100414 6 0 Xylenes 1330207 28 1 n -Hexane 110543 1,000 50 224 TMP 540841 4 0 Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on 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. Page 9 of 11 COLORADO Au Pollution Control Division Department of Public Health &'Environment Dedicated to protecting and improving the health and environment of the people of Colorado 5) The emission levels contained in this permit are based on the following emission factors: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx 7.35 * 10-4 7.35 * 10-4 AP -42: Ch. 13.5 CO 3.35 * 10-3 3.35 * 10"3 VOC 5.05 * 10-1 2.53 * 10"2 ProMax/AP- 42: Ch. 5.2, Equation 1 Benzene 71432 8.43 * 10-4 4.22 * 10-5 Toluene 108883 7.14 * 10-4 3.57* 10-5 Ethylbenzene 100414 5.48 * 10"5 2.74 * 10"6 Xylene 1330207 2.37 * 10-4 1.18 * 10-5 n -Hexane 110543 8.47 * 10 3 4.23 * 10-4 224 TMP 540841 2.99 * 10"5 1.50 * 10-6 The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 18.5 psia M (vapor molecular weight) = 45.73 lb/lb-mot T (temperature of liquid loaded) = 526 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the VOC emission factor by the ratio of the mass fraction of each NCRP in the vapors to the mass fraction of VOC in the vapors. Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must 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 Page 10 of 11 COLORADO Air Pollution Control Division Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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, CO, NOx, n -Hexane, Total HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart UUUU 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 Page 11 of 11 Co orlde Air PE'rrni'th ng Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package It: 414411 Received Date: 8/7/2019 Review Start Date: 9/19/2019 Section 01- Facility Information Company Name: PDC Energy, Inc. County AIRS ID: 123 Plant AIRS ID: A078 Facility Name: McNear 10-9 Pad Physical Address/Location _ . ..... County: Type of Facility: Exploration & Production Well Pad What industry segment? Oil & Natural Gas Production & Processing Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? D Carbon Monoxide (CO) Weld County Section 02- Emissions Units In Permit Application ElParticulate Matter (PM) Quadrant Section Township Range NWSE 9 6N 66 El Drone (NOx & v0C) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Condensate Tank TNI(1-6 Yes 19WE0810 1 Yes. Permit Initial Issuance Analysis pages hidden in this workbook - see PA for 19WE0810.CP1 for analysis of point 001. 002 Liquid Loading LOAD -1 Yes 19WE0811 1 Yes Permit Initial Issuance Section 03 - Description of Project Applicant proposes permitting of one condensate tank battery and one Ioadout operation at an O&G production facility which was newly constructed in the NAA in Weld County in August, 2019. Facility/Project both Synthetic minor for VOC - project requires Public Notice period. Section 04- Public Comment Requirements Is Public Comment Required? Yes If yes, why? Requesting Synthetic Minor Permit Section 05- Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06- Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) No Yes S02 NOx CO VOC PM2.5 f PM10 TSP HAPs J Is this stationary source a major source? No If yes, explain what programs and which pollutants herr SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) [ Non -Attainment New Sourm Review (NANSR) ii•ioroca:tcr,. Loai:; _ _ :1.SSi6:'S love. -.: ; 002 Liquid Loading Facility AIRs ID: 123 County AO7B 002. Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Is this loadout controlled? Collection Efficiency: Control Efficiency: Condensate loadout from storage tanks to trucks. ECD Requested Overall VOC& HAP Control Efficiency %: Section 03 - Processing Rate information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput= 118,085 Barrels (bbl) per year Potential to Emit (PTE) Volume Loaded = 118,085 Barrels (bbl) per year 100,0 95 98,402 Barrels (bbl) per year Actual Volume Loaded While Emissions Controls Operating = 68,402 Barrels (bbl) per year Requested Monthly Throughput= 10029 Barrels (bbl) per month Secondary Emissions - Combustion Device(s) Heat content of waste gas= Volume of waste gas emitted per year = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 2582 Btu/scf > .. set/year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate env Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility being permitted? Loading Loss Equation L =12,46*S*P*M/T Yes _ _• MMBTU per year MMBTU per year MM BTU per year *** SEE TECHNICAL ANALYSIS NOTES 000 Factor Meaning Value Units Source 5 Saturation Factor ...,„//Jy'„y,,_ AP -42 Chapter 5[2 Table 5.21 Submerged Loading: Dedicated Normal Service'(5=0.6) P True Vapor Pressure 18.5 psia ProMax Stream Callous M Molecular Weight of Vapors 45.73 Ib/Ib-mol ProMax. T Liquid Temperature 525.67 Rankine Avg Ambient Temp L Loading Losses 12,0317561) lb/1000 gallons .. 5t7> ,: lb/bbl Component Mass Fraction Emission Factor Units Source Benzene 0.0016687 ,- 0.00084325 lb/bbl ProMax Toluene 0.0014128 0.0007139.36 lb/bbl ProMax Ethylbenzene, 0.00010849 '. '' i •4823'>E 05 Ib/bbl ` ProMax Xylene 0.0004682. 00002.3„53; Ib/bbl ProMax n -Hexane 0.01676 - 0.80846639d lb/bbl ProMax 224 TMP = 0.000059241 294505E-051b/bbl ProMax Emission Factors Hydrocarbon Loadout Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Volume Loaded) (Volume Loaded) VOC 5.02E al ...AN Oe Site Specific AP -42: Chapter 5.2, Equation Site Specific -AP -42: Chapter 5.2, Equation l' Site Specific -AP -42: Chapter 5.2, Equalso1 Site Specific- AP -42: Chapter 5.2, Equat an 1 Site Specific -:AP -42: Chapter 5.2;.Equation .1 Site Specific - AP -42: Chapter 5.2, Equation 1 Site Specific -AP -42: Chapter 5.2, Equation l: Benzene :3tt1=14 -i 2?E•OS Toluene . 14134 ?S7£.95 Ethylbenzene i 22.1 ".S 2.Y?E-06 Xylene 2.217E n4 2.18E 05 n -Hexane 2.47£ 03 4.2;004 224TMP _ 55? 05 .1.50S,2. Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MM Btu) (lb/bbl) (waste heat combusted) (Volume Loaded) PM10 0290E*ut ter 3.5 Mai a• i A _K-er 13.51ndustrial'Fla S _ PM2.5 0.00F •00 SOx 0 301 M0 NOx 0.0680 7 35E 04 CO 0.3100 "t ;5t,, 2 of6 K:\PA\2019\19 W E0811. C P1 Hydrocarbon Loadout Emiss,ons Inventory 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) (tans/year) Requested Monthly Limits Controlled (lbs/month) PM10 PM25 SOx I NOx VOC CO 0 C 000 000 OCR 00E 0 090 000 000 O 0 Dun 0 000 901. 030 000 C30 0 004 C04 004 00 00 7 29 84 24 38 12 29 8 1 5 253 023 C16 016 02 02 34 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) Ohs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) I Benzene Toluene Ethylbenzene Kylene n Hexane 224 TMP 100 33 4 102 5 84 70 4 34 6 5 3 5 0 28 23 z 23 1 vGtO 833 42 - 1000 50 4 3 0 4 0 () Section 06 Regulatory Summary Analysis Regulation 3 Parts A B 5ni. ce req.n es a I el m RACT Regulation 3 Part B Section III D 2 a (See regulatory applicability worksheet for detailed analysis) 'he ioadout rius— opera`e with sabn arced fill and loaoout em ssions mu<t be cured o flare to satisfy PACT Section 07 Initial and Periodic Sampling and Testing Requirements Does the company request a control device efficiency greater than 95/ for a flare or combustion deviceo 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 _ _ ••• While the operator did submit a stabilized oil sample along with project the site specific emission factors were estimated based on the sales oil/condensate stream from a Promax model I compared those operator calculateddvalues to those calculated using the stabilized oil sample Using parameters from Promax fesults in significantly more conservative emission factors which I discussed with the operator The operator desires to maintain'these more conservative emission factorsat this time which is acceptable ••• I r HAP emission factors calculated in PA are yightly different but within rounding error Will base emissions and permit on those emission factors submitted by the operator in the APEN Per APEN Contingency loading of condensate from storage tanks Truck loading emissions controlled by ECD with DRE of 95% Truck loading emissions are only expected to occur during LACT unit downtime I` Section 09 Inventory SCC Coding and Emissions Factors AIRS Point 002 Process 9 SCC Code 01 a-00 001 32 C do O i Sabmer9cd Loan i 15 Ta n ai Sc-tiec (S=0 6) r Uncontrolled Emissions Pollutant Factor Control 9' Units PM10 0 CO 0 lb/1 000 gallons transferred PM2 5 0 00 0 lb/1 000 gallons transferred SOx 000 9 lb/1 000 gallons transferred NOx 0 0< 0 lb/1 000 gallons transferred VOC 12 0 05 lb/1 000 gallons transferred CO 0 00 0 Ib/1000 gallons transferred Benzene ' 002 / 9. lb/1 000 gallons transferred Toluene 002 90 lb/1 000 gallons transferred Ethylbenzene 3 03 95 lb/1 000 gallons transferred Kylene 0 0a 95 lb/1 000 gallons transferred n Hexane 0 ZC 95 lb/1 000 gallons transferred 224 TMP 0 00 93 lb/1 000 gallons transferred l 3 of 6 K \PA\2019\19WE0811 CP1 Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements. ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11:0.1.0)? 2. Is the loadout located at an exploration and production site le.g., well pad) (Regulation 3, Part B, Section II.D,1.I)? 3. - Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? 5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10TPY or CO emissions greater than lO TPY (Regulation 3, Part e, Section 11.0.3)? 'V Ivve indicated -h t uvice is __ Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the loadout located at an exploration and production site(e.g., well pad) (Regulation 3, Part B, Section Il.D.1.1)? 3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? 4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill? S. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facil0y uncontrolled VOC emissions from the greater than 2 TPY, NO3 greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.2)? Yes Yes No No...:=r':.... N' Yes 7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section lliD.2.a)? ITiLs iossoui_ suss., MIan A iiaz_, mui of[E"__s satisfy RACT. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any ether legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,""should,"and tan," is intended to describe APCD interpretations and. recommendations. Mandatory terminology such as "must" and "required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. yes Go to next Go to then Go to next Ge to next Go to next The loadou COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name SRC Energy, Inc. County AIRS ID 123 Plant AIRS ID A07B Facility Name McNear 10-9 History File Edit Date 09 September 2020 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) AIRS PERMIT Description PM10 PM2.5 ID VOC HAPs H2S SO2 NOx VOC Fug CO Total 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 Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 001 19WE0810 Condensate Tanks (6-400 bbl) 2.1 1192.5 9.8 26.9 2.1 23.9 9.8 0.5 New 002 19WE0811 Condensate Loadout 0.0 29.8 0.2 0.6 0.0 1.5 0.2 0.0 New 003 GP08 Produced Water Tanks (2-400 bbl) 0.1 17.2 0.6 1.2 0.1 5.9 0.6 0.1 New 004 GP02 RICE 1150 Hp 0.1 0.1 5.6 9.8 27.6 2.6 0.1 0.1 5.6 7.8 16.7 1.3 No change 005 GP02 RICE 550 Hp 0.1 0.1 39.5 3.8 66.4 0.5 0.1 0.1 2.7 3.8 8.0 0.5 No change 006 GP02 RICE 550 Hp 0.1 0.1 39.5 3.8 66.4 0.5 0.1 0.1 2.7 3.8 8.0 0.5 No change 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 FACILITY TOTAL 0.3 0.3 0.0 0.0 86.8 1256.9 0.0 171.0 32.5 0.3 0.3 0.0 0.0 13.2 46.7 0.0 43.3 3.0 VOC: Syn Minor (PSD, NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor B, T, X, HCHO & Total HH: Syn Minor + affected Area 7777• Svn Miner Permitted Facility Total 0.2 0.2 0.0 0.0 10.5 42.9 0.0 35.3 2.4 Excludes units exempt from permits/APENs (A) Change in Permitted Emissions 0.2 0.2 0.0 0.0 10.5 42.9 0.0 35.3 Pubcom & modeling (not) required based on (A change in emissions) Note 1 Total VOC Facility Emissions (point and fugitive) (A) Change in Total Pe mitted VOC emiss ons (point and fugitive) 46.7 - Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy 42.9 Page 5 of 6 Printed 9/9/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs 123 A07B McNear 10-9 Emissions - uncontrolled (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP TOTAL (tpy) 001 19WE0810 Condensate Tanks (6-400 bbl) 6129 4853 345 1571 40790 148 26.9 002 19WE0811 Condensate Loadout 100 84 6 28 1000 4 0.6 003 GP08 Produced Water Tanks (2-400 bbl) 929 725 56 192 592 0 1.2 004 GP02 RICE 1150 Hp 3773 720 443 38 215 2.6 005 GP02 RICE 550 Hp 732 100 94 56 109• 0.5 006 GP02 RICE 550 Hp 732 100 94 56 109 0.5 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL (tpy) 2.6 0.5 0.3 3.7 2.8 0.2 0.9 21.2 0.2 0.1 32.5 Emissions with controls (Ibs per year POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n -Hexane McOH 224 TMP TOTAL (tpy) 001 19WE0810 Condensate Tanks (6-400 bbl) 123 97 7 31 816 3 0.5 002 19WE0811 Condensate Loadout 5 4 0 1 50 0 0.0 003 GP08 Produced Water Tanks (2-400 bbl) 46 36 3 10 30 0 0,1 004 GP02 RICE 1150 Hp 1110 720 443 38 215 1.3 005 GP02 RICE 550 Hp 732 100 94 56 109 0.5 006 GP02 RICE 550 Hp 732 100 94 56 109 0,5 0,0 0.0 0.0 0,0 0.0 0.0 TOTAL (tpy) 1.3 0.5 0.3 0.2 0.1 0.0 0.0 0.4 0.2 0.0 3.0 6 19WE0811.CP1 9/9/2020 Condensate Storage Tank(s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.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: "hlre.l,G 8>' QJ AIRS ID Number: / � !Aar', I ' Gl ( [Leave blank unless APCD has already assigned a permit ?, and AIRS ID] Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: McNear 10-9 Pad Site Location: NWSE Sec. 9 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211111 Contact Person: Phone Number: E -Mail Address2: Brad Rogers (970) 475-5242 brogers@srcenergy.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 the APCD via e-mail to the address provided. '19#(! Form APCD-205 Condensate Storage Tank(s) APEN Revision 3/2019 1 I AV COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit ri and AIRS ID Section 2 - Requested Action ▪ NEW permit OR newly -reported emission source 0 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $312.50 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 name3 ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) OR • APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PIE) Additional Info & Notes: 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 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: Company equipment Identification No. (optional): For existing sources, operation began on: Storage of condensate from production wells TNK 1-6 For new or reconstructed sources, the projected start-up date is: 05/09/2019 Normal Hours of Source Operation: 24 Storage tank(s) located at: hours/day 7 days/week 52 weeks /year ❑✓ Exploration a Production (E&P) site ❑ Midstream or Downstream (non EEcP) site Will this equipment be operated in any NAAQS nonattainment area? Yes No O ■ Are Flash Emissions anticipated from these storage tanks? Yes No Q ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No p ■ If "yes", identify the stock tank gas -to -oil ratio: 0.00372 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes O No 0 Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIS emissions ≥ 6 ton/yr (per storage tank)? Yes No ■ Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 3 /2019 �� COLORADO 0 Upward ❑ Horizontal Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit n and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limits (bbl/year) Condensate Throughput: 984,022 1,180, 848 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 43.6 degrees ❑ Internal floating roof Tank design: 0 Fixed roof RVP of sales oil: 7.9 ❑ 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) TNK 1-6 6 2,400 04/2019 05/2019 Wells Serviced by this Storage Tank or Tank Battery6 (HIP Sites Ony) API Number Name of Well Newly Reported Well 05 - 123 - 47512 McNear 7C -7-L SI 05 - 123 - 47513 McNear 28C -7-L IS 05 - 123 - 47514 McNear 25N -7A -L l7 05 - 123 - 47515 McNear 2N -7A -L SI 05 - 123 - 47516 McNear 21 N -7A -L SI 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.50068/-104.78163 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) IES-1 27.21 1,076 451.4 i 0.16 Indicate the direction of the stack outlet: (check one) O Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular O Square/rectangle O Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): 92 Interior stack width (inches): Interior stack depth (inches): Form APCD-205 Condensate Storage Tank(s) APEN - Revision 3/2019 ®� COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit ? and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: Combustion Device: Pollutants Controlled: VOCs and HAPs Rating: 276.59 Type: Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 1,076°F MMBtu/hr C Make/Model: (4) 96" I ES 98 98 % Waste Gas Heat Content: Constant Pilot Light: E Yes ❑ No Pilot Burner Rating: 2,553 0.058 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)? 18.9 psig Describe the separation process between the well and the storage tanks: (12) 36" Worthington 3 -phase separators each rated at 0.5 MMBtu/hr, (6) non -fired 2 -phase vertical separators, and (1) 72" Dragon Manufacturing gas buster rated at 1.00 MMBtu/hr. Form APCD-205 Condensate Storage Tank(s) APEN - Revision 3/2019 Aftwir COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit a and AIRS ID) Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. 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 Enclosed Combuster 98% NOx CO HAPs Enclosed Combuster 98% Other: From what year is the following reported actual annual emissions data? 201 9 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions8 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) VOC 2.020 Ibs/bbl ProMax 993.70 19.87 1,192.46 23.85 NOx 0.068 Ib/MMBtu AP -42 N/A 1.78 N/A 2.16 CO 0.31 Ib/MMBtu AP -42 N/A 8.13 N/A 9.84 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor? Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions8 (pounds/year) Benzene 71432 5.19E-03 lbs/bbl ProMax 5,107.08 102.14 Toluene 108883 4.11E-03 Ibs/bbl ProMax 4,044.33 80.89 Ethylbenzene 100414 2.92E-04 Ibs/bbl ProMax 287.33 5.75 Xylene 1330207 1.33E-03 lbs/bbl ProMax 1,308.75 26.17 n -Hexane 110543 3.45E-02 Ibs/bbl ProMax 33.990.86 679.82 2,2,4- Trimethylpentane 540841 1.25E-04 lbs/bbl l ProMax 123.00 2.46 5 Requested values will become permit limitations. Requested limit(s) should consider future growth. 7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 3/2019 ®Y COLORADO Permit Number: AIRS ID Number: I 1 [Leave blank unless APCD has already assigned a permit tl and AIRS ID) Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. ze, 19 Signature of Legally Authorized Person (not a vendor or consultant) Brad Rogers Name (print) Date Health and Environmental Manager 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) 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 $191.13 and the General Permit registration fee of $312.50, 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 Condensate Storage Tanks) APEN - Revision 3/2019 6 I �® COLORADO E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: SRC Energy, Inc. Source Name: McNear 10-9 Pad - Condensate Tanks Emissions Source AIRS ID2: 123 I/40113/4o t Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 47517 McNear 2C -7-L /1 05 - 123 - 47518 McNear 25C -7-L 11 05 - 123 - 47519 McNear 28N -7B -L /ZI 05 - 123 - 47520 McNear 2N -7C -L ►,1 05 - 123 - 47521 McNear 21 N -7C -L 05 - 123 - 47522 McNear 7N -7C -L /1 05 - 123 - 47523 McNear 7N -7B -L /1 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - I - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 APCD-212-COND Tank-Addendum.docx Hydrocarbon Liquid Loading APEN Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment for a new filing fee. This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit, condensate storage tanks, 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: AUG - 7 X)19 //9L/E-067H AIRS ID Number: 123 /AC/Y.7g / 661. - [Leave blank unless APCD has already assigned a permit r and AIRS ID[ Section 1 - Administrative Information Company Name': SRC Energy, Inc. Site Name: McNear 10-9 Pad Site Location: NWSE Sec. 9 T6N R66W Mailing Address: (Include Zip Code) 5400 W. 11th Street, Suite C Greeley, CO 80634 Site Location County: Weld NAICS or SIC Code: 211 111 Contact Person: Brad Rogers Phone Number: (970) 475-5242 E -Mail Address2: brogerS@srcenergy.com 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt 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 the APCD via e-mail to the address provided. g/P-LOO Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 alt) COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 2 - Requested Action ❑r NEW permit OR newly -reported emission source ❑✓ Request coverage under construction permit 0 Request coverage under General Permit GP07 If General Permit coverage is requested, the General Permit registration fee of $312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info Et Notes: Truck loading emissions controlled by ECD with DRE of 95%. Truck loading emissions are only expected to occur during LACT unit downtime. 3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted. 4 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: Contingency loading of condensate from storage tanks. Company equipment Identification No. (optional): LOAD -1 For existing sources, operation began on: N/A For new or reconstructed sources, the projected start-up date is: 05/09/2019 Will this equipment be operated in any NAAQS nonattainment area? Yes 0 No El Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Yes No • p Does this source load gasoline into transport vehicles? Yes No ■ p Is this source located at an oil and gas exploration and production site? Yes No GI ■ If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Yes No • El Does this source splash fill less than 6750 bbl of condensate per year? Yes No ■ p Does this source submerge fill less than 16308 bbl of condensate per year? Yes No ■ PI Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 21 AY COLORADO Permit Number: AIRS ID Number: [Leave blank, unless APED has already assigned a permit and AIRS ID] Section 4 - Process Equipment Information Product Loaded: p Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 118,084.80 bbl/year Actual Volume Loaded: This product is loaded from tanks at this facility into: Tank Trucks (e.g. "rail tank cars" or "tank trucks") 98,402.00 bbl/year If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of 66 bulk liquid loading: True Vapor Pressure: 18.5 Psia®60'F Molecular weight of 45 73 displaced vapors: lb/lb-mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year Product Density: N/A lb/ft3 Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 �Y COLORADO Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit e and AIRS ID] Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.50068/-104.78163 �- Operatot Stack ID No Discharge Height Above Ground Level'. (feet) Temp ('F) Flow.;Rate -(ACF1) Velocity .; (ft/sec) - LEED-1 25.58 1,076 97.2 0.15 Indicate the direction of the stack outlet: (check one) ✓❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter (inches): 0 Other (describe): ❑ Upward with obstructing raincap 44 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. ❑ Loading occurs using a vapor balance system: Requested Control Efficiency: % ❑ Combustion Device: Used for control of: VOCs and HAPs Rating: 15.06 MMBtu/hr Type: Enclosed Combuster Make/Model: Leed 48" Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: 1,076 "F Waste Gas Heat Content: 2,582 Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 0.058 MMBtu/hr ❑ Other: Pollutants Controlled: Description: Requested Control Efficiency: COLORADO Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit It and AIRS ID] Section 7 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. 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) PM SOx NO. CO VOC Enclosed Combuster 95% HAPs Enclosed Combuster 95% Other: ❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane D Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL O Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2019 Criteria Pollutant Emissions Inventory Pollutant Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Uncontrolled Basis Units Source (AP -42, Mfg., etc.) Uncontrolled Emissions (tons/year) Controlled Emissions6 (tons/year) Uncontrolled Emissions (tons/year) Controlled Emissions (tons/year) PM N/A N/A N/A N/A N/A N/A N/A SOx N/A N/A N/A N/A N/A N/A N/A NO. 0.068 lb/MMBtu AP -42 N/A 0.02 N/A 0.04 CO 0.31 lb/MMBtu AP -42 N/A 0.08 N/A 0.18 VOC 5.05E-01 Ibs/bbl ProMax 24.84 1.24 29.81 1.49 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor Actual Annual Emissions Uncontrolled Basis Units i Source (AP -42, Mfg., etc.) Uncontrolled Emissions (pounds/year) Controlled Emissions 6 (pounds/year) Benzene 71432 8.42E-04 lbs/bbl ProMax 82.90 4.14 Toluene 108883 7.13E-04 lbs/bbl ProMax 70.18 3.51 Ethylbenzene 100414 5.48E-05 lbs/bbl ProMax 5.39 0.27 Xylene 1330207 2.36E-04 lbs/bbl ProMax 23.26 1.16 n -Hexane 110543 8.46E-03 lbs/bbl ProMax 832.72 41.64 2,2,4- Trimethylpentane 540841 2.99E-05 lbs/bbl ProMax , 2.94 0.15 Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 AV COLORADO 5 � ' Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source is and will be operated in full compliance with each condition of General Permit GP07. Signature of Legally Authorized Person (not a vendor or consultant) Date Brad Rogers Health and Environmental Manager Name (print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 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 $191.13 and the General Permit registration fee of $312.50, 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 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692.3148 APCD Main Phone Number (303) 692-3150 Or visit the APCD website at: https://www.colorado.gov/cdphe/aped Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019 6I AV COLOR ADO ps, Hello