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Home My WebLink About20202128.tiff COLORADO ay Department of Public Health Et Environment RECEIVED JUN 1 5 2020 Weld County - Clerk to the Board 1150 O St WELD COUNTY PO Box 758 COMMISSIONERS Greeley, CO 80632 June 10, 2020 Dear Sir or Madam: On June 11, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC Energy, Inc. - Cecil's Kersey Farm 17 Sec HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator `fl :co'ti 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe ,� r°1� �' '. Jared Potis, Governor I Jill Hunsaker Ryan,MPH, Executive Director I E. *'. Pub l; G Rev;e 0 CC PL(TP) ii t.(03) pt�J(SH/ER/cH/cbe), 6. N 2020-2128 08-/l7 J„2o 0or/II/20 • 47 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE M Comment Website Title: PDC Energy, Inc. - Cecil's Kersey Farm 17 Sec HZ - Weld County Notice Period Begins: June 11, 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: Cecil's Kersey Farm 17 Sec HZ EEtP Well Pad NWSW Sec 17 T5N R64W Weld County The proposed project or activity is as follows: The applicant proposes new permit limits based on reduced throughput and previously approved site-specific emission factors. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE1261 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 COLORADO 1 °°'° Department of Public ` Health&Environment ...-:• COLORADO Air Pollution Control Division C n Department of Pubtc Health b£nvlronment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 17WE 1261 Issuance: 2 Date issued: Issued to: PDC Energy, Inc. Facility Name: Cecil's Kersey Farm 17 Sec HZ Plant AIRS ID: 123/9F7C Physical Location: NWSW SEC 17 T5N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description- Description ID TK-1 001 Twenty (20) 538 barrel fixed roof storage Enclosed Flare vessels used to store condensate 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self-certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type TK-1 001 --- 1.1 12.4 2.2 Point Page 1 of 9 a _ ,..,..r. COLORADO �ii�� Air Pollution Control Division Department of Public Health fr Envtrortment Dedicated to protecting and improving the health and environment of the people of Colorado Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual 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 actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 3. 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. 4. 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 AIRS Pollutants Equipment Control Device ID Point Controlled TK-1 001 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 5. 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, ILA.4.) Process Limits Facility AIRS Equipment Point Process Parameter Annual Limit ID TK-1 001 Condensate throughput 181,980 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 6. 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) Page 2 of 9 C44061011COLORADO 110 Air Pollution Control Division Department of Pubttc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 7. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 8. 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) 9. 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 Il.B.2.d. 10. 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. 11. 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. 12. 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 13. 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 Page 3 of 9 C4 ..,• : t COLORADO Air Pollution Control Division COPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the 00M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 14. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 15. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 16. All previous versions of this permit are cancelled upon issuance of this permit. 17. 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. Page 4 of 9 Q...y� � COLORADO Air Pollution Control Division Niiiel Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 18. 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 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operators agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. Page 5 of 9 �� x y:•x.� COLORADO Air Pollution Control Division COPHE Department of Pubhc Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 May 29, 2018 Issued to PDC Energy, Inc. Permit for condensate storage vessels at a new synthetic minor well production facility. Issuance 2 This Issuance Updated throughput and emissions limits. Page 6 of 9 C ��:,.j COLORADO �r1 Air Pollution Control Division 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. SIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 11,068 53 Toluene 108883 1,397 70 Ethylbenzene 100414 43 2 001 Xylenes 1330207 503 25 n-Hexane 110543 9,833 492 2,2,4- 540841 59 3 Trimethylpentane 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: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 0.0122 0.0122 TNRCC Flare CO 0.0244 0.0244 Emissions Guidance VOC 2.7336 0.1367 Promax Page 7 of 9 ,:.,.. COLORADO Y� Air Pollution Control Division �l� Department cf Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl 71432 Benzene 0.0059 2.94 * 10-4 108883 Toluene 0.0077 3.84 * 10"4 100414 Ethylbenzene 0.0002 1.18 * 10-5 1330207 Xylene 0.0028 1.38 * 10.4 110543 n-Hexane 0.0540 2.70 * 10.3 540841 2,2,4 0.0003 1.62 * 10"5 Trimethylpentane Note: The controlled emissions factors for this point are based on a control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN 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 Status Requirement Operating Permit Synthetic Minor Source of: VOC PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC 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: 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 Page 8 of 9 ��",�Y-`z,,�� COLORADO 4110 ` r Air Pollution Control Division `�3� Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Bus Fischbach Package#: 429502 Received Date: 4/24/2020 Review Start Date: 55;15/2020 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section Township Range County AIRS ID: 123 NWSW 17 50 Plant AIRS ID: ISF7C Facility Name: Cecil's Kersey Fenn Z7 sec HZ Physical Address/Location: --.-fsw huad,arq.-eh Suction 17,Township hip Sr;4, County: Weld 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? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only Permit# AIRS Point# Emissions (Leave blank unless issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit 001 Storage Tank TK-1 Sos 17WE1261 2 No Modification Section 03-Description of Project Applicant is requesting new permit hmos-and ieombrig actual 2019 throughput while calculvting emissions based on the previously approved ISEts.,withthis rnodification the applicant is requesting a netv synthetic minor permit limit,and this project;Mil therefore require public comment. Self-certification and intiai testing requirements have previuosly been satisfied,and an FA letter issued for the initial issuance.As this permit modification only involves a decrease€n throughput and the permit includes minimal new requirements conditions(Must use emission factors from NTPH,new annual reporting condition),will sgain issue as FA. Sections 04,05&l&-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes" If yes,why? .Requesting Synthetic Minor or 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. Shction 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: sot Nox CO VOC PM2.5 PM10 TSP RAPS Prevention of Significant Deterioration(PSD) _ ❑ ❑ Title V Operating Permits(OP) ILIi Non-Attainment New Source Review(NANSR) 1 Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 Nox CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) E ❑ — ❑ ❑ Title V Operating Permits(OP) ILIF Non-Attainment New Source Review(NANSR) . - -:s)Emissions Inventory Section 01-Administrative Information 'Facility AIRs ID: 123 9F7Cr01 County Plant Point Section 02-Equipment Description Details Storage Tank Liquid 1 �''q,Y 7•I Detailed Emissions Unit Tµrenty(20j33&ivf edcaoftanksused for storage o condensate. t' Description: _...,,- - ? w.. ₹ {. Emission Control Device ECU Description: ss a try .-. ., Requested Overall VOC&HAP Control Efficiency%: Limited Process Parameter .? a Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= 151,653.0 Barrels(bbl)per year Requested Permit LimitThroughput= 181,980.0 Barrels(bbl)per year Requested Monthly Throughput= 15455.1 Barrels(bbl)per month Potential to Emit(PTE)Condensate Throughput= ₹„ 181,980.0.Barrels(bbl)per year Secondary Emissions-Combustion Device(s) y� Heat content of waste gas "Btu/scf Volume of waste gas emitted per BBL of liquids produced= ' scf/bbl Actual heat content of waste gas routed to combustion device= 13,11 MMBTU per year Requested heat content of waste gas routed to combustion device= 15 131 3 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 15,117:.. MMBTU per year CP1 PA explains how operator used a more conservative method to calculate heat Control Device - content to combustion device for that issuance.Re-using that calculation method Pilot Fuel Use Rate: +,:,- y ”" scfh 9.�7 MMscf/yr and the same as property g p p rty parameters(MW, Pilot Fuel Gas Heating Value: --. - ,t..Btu/scf 4.G MMBTU/yr HV,VOC%)from the initial issuarce(or even by using more conservative parameters from Section 04-Emissions Factors&Methodologies the current APEN)yields lower combustion emissions than what operator reported on Will this storage tank emit flash emissions? - APES.As the operator's current calculations re more conservative,will accept and use in Condensate Tank permitting Combustion emissions based on Actual heat content to combustion device Uncontrolled Controlled calculated by operator,and scaled based on Pollutant (lb/bbl) (lb/bbl) Emission Factor Source throughputs (Condensate (Condensate Throughput) Throughput) ®® e ry ) Previously Approved .. .. '.15IfIZIM= 013059 '-sew�� Previously Approved Previously Approved ®® hsf1e d�? - Previously Approved - - 0,0028 1.380,04 ,f r Previously Approved A t ks Previously Approved R1H e5 t7asrcp - r Previously Approved Control Device Uncontrolled Uncontrolled Pollutant (lb/MMBtu) )lb/hbl) Emission Factor Source (waste heat (Condensate om busted) Throughput) moimemommon Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) IREM 2 of 7 K:\PA\2017\17W E1261.CP2 Storage Tanks).Emissions Inventory Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Omits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (Ibs/month) PM10 0.0 0.0 0.0 0-0 0,0 PM2.5 0.0 0.0 00 0.0 0-. 0.0 50x 0.0 1,0 0.0 0,0 ac 0.0 NOx 1.1 3.53 0.43 1.11 971 188.8 VOC 248.7 207.3 "14 243.7 2112 5 CO 2,2 1.35 0.00 2.22 2.25 375.3 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (Ibs/year) (Ibs/year( (Ibs/year) Benzene :r9A800.0 44,5 1068 Toluene ._?0.7 010--,2 53.2 1047 Ethylbenzene 43.0 35.8 25 43 Xylene 503,3 4_5.4 21.0 503 .... n-Hexane 9832.8 8184.0 405.7 3333 a.50 224 TMP 59.0 4_.2 2.5 59 3 Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source,requires-oarnnr Regulation 7,Part Election I.C,D,E,F Sto _tank is so Neat r, r.0,Section I.C-F Regulation 7,Part D,Section l.G,C Storage k is no:sut. 7,Section I.G Regulation 7,Part D,Section 1L.B,C.1,C.3 Storage tank P nisei r.._,0pctlon II,B,C,18 0.3 Regulation 7,Part Election lLC2 I._ _.,action 11.0.2 Regulation 7,Part Election II.C.4.a,(i) Stomp p 0,Section II,l.4,e)i( Regulation 7,Part D,Section ILC.4.a.(ii) Storage _ _ ar t D,Section II.C 4,o)05 b Regulation 6,Part A,NSPS Subpart Kb 5fer=_-e Tank is not subject to NIPS Kh Regulation 6,Part A,NIPS Subpart 0000 5toragetaok:s not noblest to NIPS OO0O. NIPS Subpart 00000 Storage Tank is not subject to NIPS 00000 Regulation 8,Part E,MACr Subpart NH Storage'Yank is not subject to rOlACT NH (See regulatory applicability worksheet for detailed analysis) • • 3 of7 K5PA\2017\17WE1261.CP2 Storage Tank(s)Emissions inventory Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions facto to €Y n" • estimate emissions? If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons UOC per year OR are the uncontrolled actual or requested emissions fora condensate storage tank estimated to be greater than or equal to 80 tpy? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? If yes and If there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample - should be considered representative which generally means site-specific and collected within one year of the application received ' r3 date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use ant older site-specific ample. 's5n If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion device? , 0 If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes See PA for CP1 for extensive notes on the original determination of site-specific emission factors for this source. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only( Uncontrolled Emissions AIRS Point# Process# SCC Cade Pollutant Factor Control% Units -- 01 PM70- -_3 0 lb/1,000 gallons Condensate throughput PM2'-5 G.Cs 0 lb/1,000 gallons Condensate throughput SOx "API 0 lb/1,000 gallons Condensate throughput NOx G.29 0 16/1,000 gallons Condensate throughput VOC 55A9 95 lb/1,000 gallons Condensate throughput CO G.5S 0 lb/1,000 gallons Condensate throughput Benzene 95 lb/1,000 gallons Condensate throughput Toluene C._8 95 lb/1,000 gallons Condensate throughput Ethylbeezene ...-_ 95 lb/1,000 gallons Condensate throughput Kyleae 307 95 lb/1,000 gallons Condensate throughput n-Hexane 1-23 95 lb/1,000 gallons Condensate throughput 224 TMP 0;01 95 lb/1,000 gallons Condensate throughput 4 of 7 K:\PA\2017\17W E1261.CP2 • Storage Tank Regulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions. Colorado Regulator3 Parts A and B-APEN and Permit Requirements ATTAINMENT 1. Are uncontrolled.actual emissions from any criteria pollutants fromthls Individual source greater than 2TP€'(Regulatlon 3,Part A,Section ll.O.l.e)? Scarce Requires an APEN.Go to 2. Is the tuci date(service date)p 12/30/2002 and not modified after 12/31/2002(See PS Mena 0501 Definitions 1.12 and114 and Section 2 for additional guidance on grandfather applicability? Gots rue%tquert on 3. Are total facility oncobrolled VOC emissions greater h STPY NOfgreater than SO TPY or CO emss'onsgeater than 10 Try(Regulation 3,Pans Section Rail? Scarce Requires a permit km(eave indicated that sours,loin the Deriver,Osior f1ON-ATTAINMENT 1. Are uncontrelledemissions from any criteria polluterds from the individual source greater than 1TPY(Regdation 3,Part A,Section 11.0.1.01? Yes Source Requires an APEN.Go to 2. Is the construction date(service date)priorto 12/30/2002 and not modified after 12/31/2002(See PS Meme 05-01 Definitions 112 andL14 and Section 2 for additional guidance on grandfather applicability)? Goto next question 3. Aretotal facility ancontrolled VOCem'esions greater than 2TPY,NOx greater than STPY or CO emissions greater than lO TPY(Regulation 3,Part B,Section ll.D.2)? Yes Source Requires a permit • Colorado Regulation],Part D.section I.C-F&G 1. Is this storage teak located In the B-hr ozone control area or any ozonenon-attain ment area or attainment,bnaintenance area(Regulation Cr,Part O,Section 1A.117 m. Continue-You have indicatedth 2. Is this storage tank located at oil and gas operations that coiled,store,or handle hydrocarbon liquids or preiuced water AND that are located at or upstream of a natural gas processing plant(Regulation 7,Part D,Senior 1.6.11? nt, Continue-You have indicatedth 3. Is thisutaragetaok located at a natural gas processing plant(Regulation 7,Part D,Section 1.61? Ho, Storage Tank is not subject to Re 4. Does thisstoragetank contain condensate? 5. Does this sioagetank exhibit"Flash'(e.g.storing non-stabilized liquids)emissions(Regulation],part 0,Section 1.0.217 G. Are unmrrtrolledactuaI emissions of the storage tank equal to or greater than 2 tans per yearVOC(Regulation 7,Part D,Section 1.D.3.a(R))? Vas...., Part D,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part e,Se000nl.C.2—Emission Estimation Procedures Part 0,Section Le—Emissions Control Requirements Part 0,Section LE—Monitoring Part 0,Section I.F—Recordkeeping and Reporting Part 0,Section I.G.2-Emissions Control Requirements • Part 0,Section I.C.1.a and b—General Requirements for Air Pollution Control Equipment—Prevention of linkage Colorado Regulation 7.Part O.Section II 1. Is thisrtaragetank located at a transmission/storage facility? .r. Continue-You have indicated It 2. Is thisstoragetank'boated at an oil and gas exploration and production operation,well productionfacility'.natural gas compressor station'or natural gas processing plant'(Regulation 7,Part e,Section 11.01? Yor Goto the next question-You ha ' 3. Does thisstoagetank have a fixed roof(Regulation],Part 0,5eRion ll.A.201? Yes:".0)ll:Goto the nextquestioa 4 Are encontrolledactual emissions of this storage tank equal to car greater than 2 tans per year VOC(Regulate',7,Part 0,Section 110.1.c1? Yes =:nova is subject to parts of Reg, Part D,Section R.8-General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part 0,Section 111.1-Emissions Control and Monitoring Provisions Pert Cr,section 111.3-Recordkeeping Requirements 5 Does the storagelank contain only"stabilized..(quid(Regulation 7,Part D Secton 11.C.2.b17 INn rilSourcels subject to all provision, -c•-, ....ail oR Part O,Section 1112 Capture nd M t g f r str Storage Tanks bled with Air Pollution Control Equipmend. Isthe controlled storage tank l cat d at welIp d R facility,naturalg pessor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified an or after May 1,2020,such • 6. that an additional cant olbd storage vessel is construned to receivea t p d increase inthroughput of hydrocarbon liquids or produced water(Regulator 7,Part D,Section II.C4aIll? Nu Storage Tank s not subject to RE Is the controlledslorage tankl boated at a wes production facility,neural g compressor station,or natural gas processing plant constructed on orafter January 1,2021 or located at afadlity that was modified on or after lanuaryl, 7. 2021,such that am additionalcontrolled storage vessel is constructedt tinpated increase in doorghput of hydrocarbon liquids or produced water(Regulation 7,Part 0,Section 11040(11)? I:or 40 CFR,Part GO,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(m)['472 BBLs](40 CFR 6ti110b(a))? Yrs Go so the next question 2. Does the storage vessel meet the fallowing exemption in 60.111b(d)(4)? Yes: Storage Tank is not subject NSPS a.❑oes she vessel has a design capacity less than or equal to 1,589.874 m'(-10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 60.1116? 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after luly 23,1584(40 CFR 60.11ob(a))? 4. Does the tank meet the definition of"storage vessel"'in 60.11167 5. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined In 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a.Is the storage vessel a pressure vessel designed to operate In excess of 204.9 bra 1-29.7 psi]andwthout emissions to the atmosphere(60.110b(d)(2)17;or b.The design apaciry is greater than or equal to 151 m5[-950 BBL)and stores a liquid with a maximum true vapor pressures less than 3.5 bra(60.110b(b))?;or c.The design capacity is greater than or equal to 75 M5[-472 BBL]but less than 151 ma['950 BBLjand stores a liquid with a maximum true vapor pressure'less than 15.0 kPa(60.110b(b))7 7. Does thestorage tankmeet either one of the following exemptions from control requirements: a.The design capacity is greater than erequalto 151 ma[-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 bra but less than 5.2 knit;or b.The d g p ity Is g t than ual to 75 M'(-472 BBL]but less than 151m'[-950 BBLjand stores a liquid wnh a maximum true vapor pressure greater than or equal to 15.0 bra but less than 27.6 kPa? I G'tf h"ins o DCPS .. 40 CFR,Part 60.Subpart 0000/00000,Standards of Performance for Crude Oil and Natural Gas Production,Tsansmisslon and Distribution 1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment, ral gas pocessing segment uralgastransmission and storage segment of the industry? Continue-You have indicated th 2. Was the storage vessel constructed,reconstructed,or modified(me definitions 40 CFR,6021 between August 23,2011 and September 18,20157 Np 'b-'Teter Storage Tank is not subject NSPS 3, West).storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,20157 YeelNW Go ta the next question 4. Are potential VOCem'sans'Pram the individual storage vessel greater than or equal to 6 tons per year? fM =_Storage Tank is not subject NSPS 5. Does this storage vessel meet the definition of"storage vesseg'per 65.5430/00.5430.? /%? 6 Is the sto rage sselsubjeor to andcontrolledl accordance with requirements for storage vessels in 40 CFR Pan 60 Subpart Kb or 40 CFR Part 63 Subpart HG? 52A11212,1 e_,rank is rear,bier lSi'ir goo,r,e [Note:If a storage vessel is previously determined to be subject's NSPS 0000/0000a duets emissions agave 6 tam per year VOC an the applicability determination date,it should remain sub]es to NSPS 0000/0000a per 60.5365(e)(21/60.5365a(e](2]even It potential COO emissions drop below 6 tons per year] 40 CFR,Part 63,Subpart MACP FHB ell and Gas Production Facilites • 1 Is the staragetanklocated at an oil and natural gas production facility that meets either of the following criteia: Ives IContlnue-You have indicatedth a.Afacildy that processes,upgrades or stores hydrocarbon liquids'(63.760(0)(2));OR b.Afacildy that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gastransmission and storage source category or is delivered to a final end user'163.760(a)(311? 2. Is the tank locatedat a facility that Is major'for HAPs? No-.. Storage Tank is not subject MAC 3. floes thetank meet the definition of"storage vessel'In 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63.761? 5. Isthe tank subject-to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 0000? Subpart A,General provisions per 563.764(a)Table §63.]66-Emissions Control Standards §63.709-Monitoring §63.738-Recordkeeping §53.775-Reporting RACT Review RACE review is required if Regulation 7 does rat apply AND if the tank Is in the non-attainment area.If thetank meets both criteria,then review RACP requirements. Discl4mer This document assists operators with determining applicability of certain requirements°fine Clean Air Act,ds implementing regulations,and Air Quality Control Commission regulations This document is not a ode or regulation,and the analysis it contains may not apply foe particular situation based upon the individual fads and circumstances.This document does not change or substitute for any law,regulation, anyother legally binding requirement and is not legally enforceable.In the event of anyxon0ict between the language of this document and the language of the Clean Air Act„its implementing regulations, and Ai'Quality Control Commission regulations,the language of the statute or regulation viii control.The use of non-mandatory language such as'recomnrend,"'may,"'slrould,"and rsan,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'oust"and"required"are intended to describe controlling requirements under the terms of the Clean Air Ad and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name PDC Enerov.Inc. County AIRS ID 123 History File Edit Date 6/8/2020 Plant AIRS ID 9F7C Ozone Status Non-Attainment Cecil's Kersey Farm 17 Sec HZ Facility Name EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS VOC HAPs VOC HAPs ID Previous FACILITY TOTAL 0.5 0.5 0.0 0.0 44.6 1,294.9 0.3 74.6 34.3 0.5 0.5 0.0 0.0 9.9 80.7 0.3 20.6 3.3 Previous Permitted Facility total 0.3 0.3 0.0 0.0 42.2 1,294.8 0.0 72.6 34.3 0.3 0.3 0.0 0.0 7.5 80.6 0.0 18.6 3.3 001 17WE1261 Twenty(20)538 bbl fixed roof 1.1 248.7 2.2 6.5 1.1 12.4 2.2 0.3 Permit modification to reduce throughput. condensate storage vessels _002 GP07 Condensate Loadout 0.4 102.5 0.8 1.7 0.4 10.0 0.8 0.1 No change(APCD102 included in application shows much smaller uncontrolled,though no APEN updates for this point have come in since original,-so will leave APEN reported value in history file). 003. GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 _0.0 Cancellation received 10/31/2019-no longer 211 HP,SN.G6X08199 exists..:: 004 GP02 SI RICE Caterpillar G3306TA,4SRB, 0.2 0.2 18.5 0.6 31.1 0.3 0.2 0.2 1.1 0.6 4.1 0.2 No change 211 HP,SN:G6X07366 005 GP05 Eight(8)400 bbl and two(2)210 bbl 3.7 1.2 10.0 1.2 No change fixed roof produced water storage vessels 006 GP02 SI RICE GM Vortex 5.7L,4SRB.92 11.8 0.6 9.3 0.1 0.8 0.6 1.7 0.1 Description and emissions based on APEN and HP(site-rated 88 HP).SN: associated application in RM8. Point has not yet 10CHMM410150016 been reviewed by an engineer.but APEN information included for full project consideration while processing mod for point 001. 0.0 0.0 0.0 0.0 XA External Combustion Sources 0.2 0.2 2.4 0.1 2.0 0.0 0.2 0.2 2.4 0.1 2.0 0.0 Insignificant Source XA Fugitives 0.3 _ 0.0 0.3 0.0 Insignificant Source 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 34.2 356,2 0.3 45.4 9.8 0.3 0.3 0.0 0.0 5.9 33.7 0.3 10.8 2.0 VOC: Syn Minor(NANSR,PSD and OP) NOx:True Minor(NANSR and OP) CO: True Minor(PSD and OP) HAPS: True Minor HH: Not applicable-area source ZZZZ: Area source Permitted Facility Total 0.2 0.2 0.0 0.0 31.8 356.1 0.0 43.4 9.8 0.2 0.2 0.0_ 0.0 3.5 33.6 0.0 8.8 1.9 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions -0.2 -0.2 0.0 0.0 -4.1 -47.0 0.0 -9.8 Modeling not required based on A change in emissions,Pubcom is required based on • requesting new syn minor permit limits. Total VOC Facility Emissions(point and fugitive) 33.9 Facility is eligible for GP02 because<90 tpy (A)Change in Total Permitted VOC emissions(point and fugitive) -47.0 Protect VOC emissions-greater than 25 ipy Note 1 Note 2 • Page 6 of 7 Printed 6/8/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name PDC Energy,Inc. County AIRS ID 123 P1001 AIRS ID 9F7C Facility Name Cecil's Rersen Farm 17 Sec HZ Emissions-uncontrolled(Ibs per year) POINTIPERMIT (Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE1261 Twenty(20)538 bbl fixed roof 1068 1397 43 503 9833 59 6.5 condensate storage vessels 002 GP07 Condensate Loadout 361.4 3136.1 1.7 00$ 5PO2,5N i SI RICECIaterpillar GS306TA;4SRB,( ., `211 HP,SN'56X08199`- _ - 004 GP02 SI RICE Caterpillar G3306TA,4SRB, 342.4 45.6 43.5 26.4 1 J 0.3 211 HP,SN:G6X07366 005 GP0S Eight(8)400 bbl and two(2)210 bbl 940 873.3 21 5 101.5 431.1 1.2 fixed roof produced water storage vessels 006 GP02 SI RICE GM Vortec 5.7L,4SRB,92 134 18 17 10 0.1 HP(site-rated 88 HP),SN: 10CHMM41 01 5 0 01 6 0.0 0.0 XA External Combustion Sources 0.0 XA Fugitives 1i II 10.7 10.8 12.3 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.2 0.0 0.0 1.2 1.1 0.0 0.3 6.7 0.0 0.0 0.0 0.0 9.8 *Total Reportable=all HAPs where uncontrolled emissions v de minimus values Red Text uncontrolled emissions=de iviremus Emissions with controls()bs per year) POINTIPEAMIT (Description Pamaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane MeOH 224IMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 1755E1261 Twenty(20)538 bbl fired roof 53 70 2 25 492 3 0.3 condensate storage vessels 002 GP07 Condensate Loadout 18.1 156.8 0.1 _... . .. GP0�.CN" s`SI,RICF Caterpillar 533©5iA,4SRB ?: 211'HP≤=SN:56X00169 _ 004 GP02 SI RICE Caterpillar G3306TA,4SRB, 285 '56.0 43.0 26,4 211 HP,SN:56X07366 005 GP05 Eight(8)400 bbl and two(2)210 bbl 940 873.3 21,5 11)1.5 431.1 1.2 fixed roof produced water storage vessels 006 GP02 SI RICE GM Vortec 5.7L,4SRB,92 134 18 17 10 0.1 HP(site-rated 88 HP),SN: t 0CHMM410150016 0.0 0.0 XA External Combustion Sources 0.0 XA Fugitives 11 '11 10., 10 H 12.3 0.0 0.0 0.0 0.0 0.0 0.0 TOTAL(tpy) 0.2 0.0 0.0 0.5 0.5 0.0 0.1 0.5 0.0 0.0 0.0 0.0 2.0 7 . 17WE1261.CP2 E1261.CP2 6/8/2020 Condensate Storage Tank(s) APENA c/{ C 440 Form APCD-205 APR 2 4 1019 CDPHE Air Pollutant Emission Notice (APEN) and ' Application for Construction Permit S „. b AU 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. 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: 17WE1261 AIRS iD Number: 123 / 9F7C /001 Section 1 - Administrative Information — —_-- Company Name': PDC Energy, Inc. Site Name: Cecil's Kersey Farm 17 Sec HZ Site Location Site Location: NWSW Sec 17 T5N R64W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Contact Person: Jack Starr Phone Number: (303) 860-5800 E-Mail Address2: Jack.Starr@pdce.com I Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. 429499 COIORA DO 7 Nat enr Permit Number: 17WE1261 AIRS ID Number: 123 /9F7C/001 Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of$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 ❑r Change permit limit 0 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(PTE) Additional Info a Notes: 2019 Actual throughput; Requesting new permit limits for Construction Permit 17WE1261; Emissions calculated using previously approved site-specific emission factors. 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: Condensate Storage Tanks Company equipment Identification No. (optional): TK-1 For existing sources, operation began on: 9/8/2017 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: ❑ Exploration&Production(E&P)site 0 Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? ❑Q Yes 0 No Are Flash Emissions anticipated from these storage tanks? 0 Yes 0 No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? ❑ Yes El No If"yes", identify the stock tank gas-to-oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) Q Yes ❑ No 805 series rules?If so, submit Form APCD-105. Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual 0 Yes ❑ No emissions≥6 ton/yr(per storage tank)? Permit Number: 17WE1261 AIRS ID Number: 123 19F701001 Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbllyear) (bbtlyear) Condensate Throughput: 151,653 181,980 From what year is the actual annual amount? 2019 Average API gravity of sates oil: 50.8 degrees RVP of sales oil: 9.5 Tank design: Fixed roof ❑ Internal floating roof ❑External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel In Production (bbl) Storage Tank(month/year) (month/year) TK-1 20 10,760 3/2017 9/2017 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 • 42902 Cecil's Kersey Farm 178-212 0 05 123 - 43895 Cecil's Kersey Farm 178-214 ❑ 05 - 123 - 42906 Cecil's Kersey Farm 178-302 0 05 - 123 • 43894 Cecil's Kersey Farm 17B-304 ❑ 05 - 123 • 42901 Cecil's Kersey Farm 17K-204 0 s Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 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 - Geographical/Stack Information Geographical Coordinates (LatitudelLangitude or UTM) 40.396743/-104.580386 r❑Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec) Indicate the direction of the stack outlet: (check one) ❑Upward ❑Downward ❑Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ❑Circular Interior stack diameter(inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): affike COLORADO 3 1 Permit Number: 17WE 1261 AIRS ID Number: 123 /9F7C/001 r . . Section 6 - Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: 0 Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model: 10 x Cimarron 48",1 x Cimarron 60" a Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 27 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator cOLORAOo 4 0.,�..r�wc. III Permit Number: 17WE1261 AIRS ID Number: 123 /9F7C/001 Section 8 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form7. Is any emission control equipment or practice used to reduce emissions? ❑r Yes ❑ No If yes, describe the control equipment AP D state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC Enclosed Combustor 100.4 95% NOx CO HAPs EndosedCombuslor 100'o I 95% Other: From what year is the following reported actual annual emissions data? 201 9 Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions Basis Aft.,etc.) (tons/year) (tons/year) (tans/year) (tons/year) VOC 2 7336 IbIDb ProMax 207 28 10 36 248 73 1244 NO. 01380 IbIMMB1u rcoc NIA 093 N/A 111 CO 0 2755 IoIMMBtu Iota NIA 1 85 N'A 222 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. 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 emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. Section 9 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteria 1❑Yes ❑ No pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant (HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Service(CAS) Units Units (AP-42, Emissions Emissions8 Number Basis Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 00059 ibrobl ProMax 89039 4452 Toluene 108883 00077 Itabbi ProMax 1.15395 5820 Ethylbenzene 100414 00002 Iblbbi ProMax 35841DM) 1791OM, Xylene 1330207 _ 00028 Ib/Obi ProMax 41944 2097 n-Hexane 110543 0 0540 Ibrobo ProMax 8 19427 409 71 2,2,4-Trimethylpentane 540841 00003 lb/bbi ProMax 4917OM) 2451DM) 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 emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide projected emissions. se COLORADO Permit Number: 17WE1261 AIRS ID Number: 123 /9F7c/001 Section 10- 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. tyt 3( , '77- e..- ,S--- - — , Sigp ure of Legally Authorized Person (not a vendor or consultant) Date Jack Starr Senior Air Quality Representative Name(print) Title Check the appropriate box to request a copy of the: QQ 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 For more information or assistance call: registration fee of$312.50, if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver, CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO 6Ii Hello