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HomeMy WebLinkAbout20202710.tiff .„., COLORADO ;44VirliiDepartment of Public Health&Environment Weld County - Clerk to the Board 1150 0 St RECEIVED PO Box 758 Greeley, CO 80632 AUG 2 1 2020 August 17, 2020 COMMISSIONERS Dear Sir or Madam: On August 18, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC Energy, Inc. - Albrighton/Heidenreich 10 Sec Pac. 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 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Id� o Jared Polls,Governor Jill Hunsaker Ryan,MPH, Executive Director I 1,, 1#1, Pub I:c Rev,sec,) cc:PL(TP),HL(D5),Pwcam/ER/C>N/CK), 2020-2710 09/o9/Zo oGCsM) O9/0 /;2a 4.,.." Air Pollution Control Division yr OD Notice of a Proposed Project or Activity Warranting Public GDPWE Comment Website Title: PDC Energy, Inc. - Albrighton/Heidenreich 10 Sec Pac - Weld County Notice Period Begins: August 18, 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: Albrighton/Heidenreich 10 Sec Pac Well Production Facility SESW quadrant of Sec 10, Township 6N, Range 67W Weld County The proposed project or activity is as follows: PDC Energy, Inc is changing permit limits for condensate tank battery. 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 deteriiination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0618 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: Diego Chimendes Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 ,�:s COLORADO Department of Public 1 c'"` Health ft Environment 411 COLORADO • w Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE0618 Issuance: 2 Date issued: XX/XX/XXXX Issued to: PDC Energy, Inc. Facility Name: Albrighton/Heidenreich 10 Sec Pad Plant AIRS ID; 123/9C1 F Physical Location: SESW SEC 10 T6N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description 1D Twelve (12) 538 barrel fixed roof Enclosed TK-1 (2) 009 condensate storage vessels connected via Combustor(s) liquid manifold. 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 Page 1 of 9 xYy COLORADO ElII 4%0i Air Pollution Control Division Ntigi Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 3. 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.) 4. 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 5. 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,t VOC CO Type TK-1 (2) 009 --- 1.0 12.8 2.1 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. 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. 6. 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. 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.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK-1 (2) 009 Enclosed Flare VOC and HAP Page 2 of 9 C0 ,„y...,::0 4401111 Air Pollution Control Division Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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 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 AIRS Process Parameter Annual Limit Equipment ID Point TK-1 (2) 009 Condensate Throughput 246,721 barrels 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. 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) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. 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) 12. 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. Page 3 of 9 21;:t... COLORADO Air Pollution Control Divisio n Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado 13. 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. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. 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 16. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OttM) 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 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. All previous versions of this permit are cancelled upon issuance of this permit. 20. 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: Page 4 of 9 • Ci "..4,-..- COLORADO Ittal Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 21. 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 22. 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. 23. 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. Page 5 of 9 Cr COLORADO Air Pollution Control Division NtitO Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 24. 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. 25. 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. 26. 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. 27. 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. 28. 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: Diego Chimendes Permit Engineer Permit History Issuance Date Description Issuance 1 02/25/2019 Issued to PDC Energy, Inc. Issuance 2 This Issuance Issued to PDC Energy, Inc. Change in requested condensate throughput and emissions limits. Page 6 of 9 CCryvv COLORADO 4 Air Pollution Control Division tte Department of Public Health&Enwonment 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 Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (Ib/yr) (lb/yr) Benzene 71432 991.9 49.6 Toluene 108883 908.1 45.4 Ethylbenzene 100414 45.5 2.3 009 Xylenes 1330207 298.0 14.9 n-Hexane 110543 9919.9 496.0 2,2,4- 540841 95.2 4.8 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 8.41x1O3 --- CDPHE CO 1.68x10-2 --- CDPHE VOC 2.076 1.04x10-1 Site Specific E.F. 71432 Benzene 4.02x10-3 2.01x1 0-4 Site Specific E.F. Page 7 of 9 Cr COLORADO Mr Pollution Control Division Department of 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 108883 Toluene 3.68x10-3 1.84x10-4 Site Specific E.F. 1330207 Xylene 1.208x10-3 6.04x10-5 Site Specific E.F. 110543 n-Hexane 4.02x10-2 2.01x10-3 Site Specific E.F. Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the outlet of the low pressure separator for the Albrighton I-10HN well on 04/17/2018. The sample pressure and temperature are 23.7 psig and 123°F respectively. 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 True Minor Source of: CO, NOx, £t HAP. Synthetic Minor Source of: VOC. PSD True Minor Source of: CO £t NOx. NANSR True Minor Source of NOx. Synthetic Minor Source of VOC. MACT HH Area/Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://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 COLORADO 40 Npi-4"kit-oP4 Air Pollution Control Division Department of Public Health&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 PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Diego Chimendes Package#: 431143 Received Date: 5/8/2020 Review Start Date: 7/8/2020 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section Township Range County AIRS ID: 123 SESW 10 6N 64 Plant AIRS ID: 9C1F Facility Name: Albrighton/Heidenreich 10 Sec Pad Physical Address/Location: oship 6N,Range 64W 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 AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering Emissions Source Type Equipment Name Action APCD has already Control? APCD has already N Required? Remarks assigned) assigned) Requesting Permit new Permit 000 Storage Tank TketAt, ves __ Yes Modification Limits Section 03-Description of Project POC Energy submitted 3 Pe.snit Moddibabob on 05/08/2020.PDC Energy wishes-v chungn the et - t limit bb ruducing thu requested Muudghpat. ..(E wai maintain_!,_soeC f c:miss n fuctor4 previously approved by the Division. Point source is:-PEN-required because unccristroiied 000 ernissimis are greater than 1 tpy and uncontrolled emissio;s of at least one non-criteria pollutant is greater than 25^0 spy.(Regulation 3 Part A Sec.ion 11.3.x.)Peiiit source is permit required because uncontrolled facility-wide VOC emissions are greater than 2 iipy. Regiiln Pon 3 Part E Section ti. Public comment€s required because operator is requesting a federally enforceable limit on the potential to emit in order to. roil other i aquirements (controlled VCS.<50 tpy).(Peculation 3 Part B Section Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer 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? d> Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) LILIOD ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ 000 Non-Attainment New Source Review(NANSR) ❑ 0 Is this stationary source a major source? If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ LILID Non-Attainment New Source Review(NANSR) ❑ 0 Section 01-Administrative Information 'Facility A1Rs ID: .123 9C1F 009.- County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Detailed Emissions Unit Twelve(12)538 barrel fixed roof condensate storage''ve eiscohgecte'dwa liquidrr4 k -" Description: 6 Emission Control Device Four(4)Cimarron 48"and One jx)Cimarron 60"enclosed - T 3iM rn Wusto,s Description: "» Requested Overall VOC&HAP Control Efficiency 10 90.0 Limited Process Parameter , yve Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actual Throughput= '205,001.0 Barrels(bbl)per year 'Requested Permit Limit Throughput= 246,721.0 Barrels(bbl)per year Requested Monthly Throughput= 2773,..s Barrels(bbl(per month Potential to Emit(PTE)Condensate Throughput :246,721.0 Barrels(bbl)per year Secondary Emissions-Combustion Device(s) 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= >.e MMBTU per year Requested heat content of waste gas routed to combustion device= -5.'1C S MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= :0.3 MMBTU per year Control Device Pilot Fuel Use Rate: -'2'76f-6.2-6,16662.7c2,7 '.scfh 0 0 MMscf/yr Pilot Fuel Gas Heating Value: ,„, - Btu/scf 0.'.1 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storage tank emit flash emissions? e1''�.< . Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (lb/bhp Emission Factarsource (Condensate (Condensate Throughput) Throughput) VOC 2.1E+00 _ Site Sa Benzene 4.0E-03 e5pec i 1 (C hlal l Toluene 3.7E-03 Ethylbenzene 1.8604 -.1 fl-a:n) Xylene 1.2E-03 n-Hexane 'bAE-02 3 -0 224 IMP 4.00-04 .I Sake} ₹ sb} Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor-Source (waste heat (Condensate combusted) Throughput) PM10 0.0025 <: _ .�...'12:5) PM2.5 0.0075 g OE i-'5 —SOx 0.0006 r1P R24.1.6; NOx 0.1300 C TNA`CCF' CO ,, '.0.2755 _ TNRCC ..-- ... fear Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (lb/MMBtu( (Ib/MMscf( Emission Factor Source (Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 PM2.5 SOx 7 v'00 NOx 0.0000 VOC C.'7200 CO 0 Section 05-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) fibs/month) PM10 ,._ - _.- 0 1 PMZ.5 _- d._ 0.1 3.3 SOx 0.0 0.0 0.0 2.0 0.0 0.0 NOx '1.0 0.9 __ 1,0 1.0 111.3 VOC 256.1 213.4 256.1 12.8 2174.9 CO 2.1 _.7 ... 2.1 2.1 :_a., Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 991.9 025.6 .. Toluene 908.1 -g8 -. »7.. Ethylbenzene 45.5 3..3 1.9 - , -. Xylene _ ___ n-Hex _,._ 224 TMP '- Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation 7,Part D,Section I.C,D,E,F Regulation 7,Part D,Section I.G,C Regulation 7,Part D,Section II.B,C.1,C.3 Regulation 7,Part D,Section II.C.2 Regulation 7,Part D,Section II.C.4.a.(i) - - Regulation 7,Part D,Section II.C.4.a.(ii) Regulation 6,Part A,NSPS Subpart Kb ... Regulation 6,Part A,NSPS Subpart 0000 NSPS Subpart 0000a Regulation 8,Part E,MACT Subpart HH (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to estimate emissions? , a^ If yes,are the uncontrolled actual or requested em ssians fora crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the ti s uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? _d< 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` c P permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)? '�qui p yin This sample x�? ' should be considered representative which generally means site-specific and collected within one year of the application teV +w i received date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to 4; i use an older site-specific sample. - - ,,13 ,<r. 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-O3. Does the company request a control device efficiency ry greater than 95%for a flare or combustion device? If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Motes t Secandacr/tmissionsCalcvtatrons - - 1.1From PA of first Issuance and original Praha,:model Tysskot'y,the secondary corn busttan_rissiosoe[_.:[Mated using thewaste gasfiaw.rate and heat content predicted by the mode, used to establish thesife-npetg?c emissions factors.Based on the ProMax su,lotion the rotai waste gas flaw rate was medieteu toneO,036432771NMscf/day(Rash and W&8 goy)Additionally an average heat content WaStleterrnined uvnAehe heat content of the flash gas steam(25 14 22 Btu/sefj and theWN&8 stream(2 7Za/Elttristf1 s ntl the following equations:Average Heat Content((2514.22 Btu/scfl'`iO 6006 misuciA0900x3643277MMscf/dayj.t(2577O7Bt,./so-mo1582657 MAMscf/srly)/(u 1ro43277 MN14/dayll 2324,27$ty/sef•" 1,2.Due tai condensate throughput reduction,it is possible lculate the new waste gas flew.:..e.12467211.ifyr)/(7?7450 bbl/yr)•0.03643277 MMscf/day=0.01235666 M;5scf/day.Using this information,the yearly heat input of the gas would be calculated as fellows-Heat tom'?iNiNigtit/yr).(0012,5666 MMscf/7a51'(365 day/'fezrt"(2524.27 lu M8tu/MMscfl=11384.91 MUM/year.Using this value;the 1400 and COernissionswould be calculated at 039 tpy and 1.76 tpy respectively. 13 From PASt first'ssuhng. "The operator used the fallowing equation to cokulate the annuat lreot input.Hecc Input(MMBtu/yr)-((lncontrniled 701(toy/yr)1`2GOo ib/tank/ROWiib/lb- mol)i`f379'ci zf/b-malj'(1/VOCcr.6j"!Kent Content(btu,&cfj'flMMBc/ 000,000Bal.The mmer alai'at _zed the values/ar molecular weight,VOCwc5 and heat content 5sed in the equation acre developed by evnitrutIngir 24teflash gas ueniyses in PrvMove.The ape:'a- fereherexpressed that the values Ore"conservative enough to be used as representative values."The values used in the.equation ore .fclimu h,Molecular tveroncoalb,lb-nra,Cur 501 wt°6:#8%,Gill Heat C me f 2000 B,u/`:f>"Usiegthese values,the operator calculated a heat input of 12533.55 MMBtu/yr.Sieve this value is more canners,,sery,AP,than the vatue.aicutatedabove using prescribed methods,it4-81he used for permitting purposes. 2.Thu sae specific sample wet to establish emiss vns factarytor this source was obtained within a year of the fast issuance application The sample was obtained from the Arbrighton 1.1085 wsii or:34/17/20'._3. Since the inreel application,,nu new wells were'ncluded to the facility nor the process has beer changed.Asa result,the operator do not need to resample and develop new sitespecific emission escrors, 4,The permit will not contain'initial or periodic opacity testing for the enclosed combustor because the O&M plan approved for this scurvy requires weekly visible en-fissions observations of the ",flare. Section 09-5CC Coding and Emissions Factors(For Inventory Use Only) Uncontrolled Emissions AIRS Paint# Process# SCC Code Pollutant Factor Control%Units �..�_ 01 PM1O ,..,,., _ lb/1,000 gallons Condensate throughput PM25 e.'31 .' lb/1,000 gallons Condensate throughput SOx lb/1,000 gallons Condensate throughput NOx e, C lb/1,000 gallons Condensate throughput VOC =9.43 .: lb/1,000 gallons Condensate throughput CO 's.,,, _ lb/1,000 gallons Condensate throughput Benzene 01- 95 lb/1,000 gallons Condensate throughput Toluene 0 95 lb/1,000 gallons Condensate throughput Ethylbenzene 0.0` 90 lb/1,000 gallons Condensate throughput Xylene 0.03 99 lb/1,000 gallons Condensate throughput n-Hexane 0.00 95 lb/1,000 gallons Condensate throughput 224 TMP 0.01 90 lb/1,000 gallons Condensate throughput• • Storage Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APES and Permit Requirements ATTAINMENT sr._,..r.T.e 1'. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY(Regulation 3,Part A,Section lI.D.1.a)7 Source Requires an APEN.Go to the next question 2. Is the construction date(service date)priorto 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? Go to next question 3, Are total facility uncontrolled VOC,emissions greater than 5TPY,NOx greater than to TPY or CO emissions greaterthan 10 TPY(Regulation 3,Part B,Section 11.0.3)7 Source Requires a permit " %.A. NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than S TPY(Regulation 3,Part A,Section ll.D.1.a)? 4�1��S3±r.'�.'Source Requires an APEN.Go to the next question ^t'5, 2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definition 1.12 end1.14 and Section 2 for additional guidance on grandfather appicabiliity)7 ) 'e `i.Go to neat question 3. Aretotal facility uncontrolled VOCemissiens greater than 2 TPY,NOx greater than 5 TPY or CO emissions greater than De TPY(Regulation 3,Part B,Section 11.0.2)7 § ti' Source Requires a permit Colorado Regulation 7,Part D.Section LC-F&G 1. Is this storagetank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section I.A.1)7 v. Continue-You have indicated the site attainment status on th 2. Is this storage tank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation],Part 0,Section l.A.1)7 .. Continue-You have indicated the facility type on the project! 3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part 0,Section 1.0)7 Storage Tank is not subject to Regulation 7,Part 5,Section 1.0 4. Does this storage tank contain condensate? or, 5. Does this storagetank exhibit"Flash'.(e.g.storing non-stabilized liquids)emissions(Regulation 7,part D,Section 1,0.2)7 6. Are uncontrolled actual emissionsof this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part 0,Section l.D.3.z(ii])7 Part 1,5ectlon I.0.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part 0,Section I.C.2—Emission Estimation Procedures - Part 0,Section 1,0—Emissions Control Requirements Part 0,Section I.E—Monitoring Part O,Section l,0—Recordkeeping and Reporting °cage agk.s .. r ...�. �.v......., Part D,Section 10,2-Emissions Control Requirements Part D,Section I.C.1.a and h—General Requirements for Air Pollution Control Equipment—Prevention of Leakage• Colorado Regulation 7,Part'',Sectios II 1. Is this storagetank located at a transmission/storage facility? Continue-You have Indicated the source category on the Proj 2. Is this storage tank'located at an oil and gas exploration and production operation,well production facility',natural gas compressor stations or natural gas processing plant°(Regulation 7,Part D,Section II.C)? Go to the neat question-You have indicated facility type on p 3. Does this storagetank have a fixed roof(Regulation 7,Part 0,Section ll.A.20)? :`.-`x'.Go to the nett question 4. Are uncontrolled actual emissionsof this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section ll.C.1.c)7 i ';.i$.'Source is subject to parts of Regulation 7,Part 0,Sections 11.0: Part D,Section II.n—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part 0,Section 11.0.1-Emissions Control and Monitoring Provisions Part 0,Section 11.0,3-Recordkeeping Requirements 5. Does the storage tank contain only"stabilized"liquids(Regulation],Part D,Section ll.C.2.6)7 "'.. Sourca is subject to all provisions of Regulation 7,Part D,Sect Part 0,Section 114 '0.2-Capture and Monitoring for5torage Tanks fitted with Air Pollution Control Equipment Is the controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified on or after May 1,2020, 6. such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section ll.C.4.a.(i)7 (4fl?'�:�''.]]IIStorage Tank is not subject to Regulation 7,Part 0,Section II. LC. Is the controlled storagetank located at a wellpoducton facility,natural gas compressor station,or natural gas processing plant constructed on orafterianuary 1,2021 or located at a feciltythat was modified on or after) ary 7, 1,2021,such that an additional controlled storage vessel is constructed to receive en anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D,Section ll.C.4.e.(t)? 40 CFR.Part 60,Subpart Kb,Standards of Performance for Volatile Organic Liquid Storage Vessels 1, Is the individual storagevessel capacity greaterthan or equal to 75 cubic meters(m s)['472 BBLs](40 CFR 60.110b(a))7 ,Go to the next question 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Storage Tanks not subject NSPS Kb. e.Doesthe vessel has a design capacity less than or equal to1,500.074 re['10,000 BBL)used for petroleum'or ondensate stored,processed,or treated prior to custody transfer'as defined in 60.111b? 3. Was this storagevessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after July 23,1984(40 CFR 6011ob(a))? 4. Does the tank meet the definition.of"storage vessel"'In 60.111b7 5. Does the storage vessel store a"volatile organic liquid(VOL)'s as defined in 60.111b7 6. Does the storage vessel meet any one of the following additional exemptions: a.Is the storage vessel a pressure vessel designedto operate in excess of 204.9 kPa["29.7 psi]and without emissions to the atmosphere(60.110b(d)(2))7;or b.The design capacity is greaterthan or equal to 151 m°[^050 BBL]and stores a liquid with a maximum true vapor pressures less than 3.5 kPa(60.1106(6))?;or c.The design capacity 1s greaterthan or equal to 75 M°['472 BBL]but less than 151 me C"950 BBL]and stores.a liquid with a maximum true vapor pressures less than 15.0 kPa)60.110b(b))7 7. Does the storage tank meet either one of the following exemptions from control requirements: rK.... a.The design capacity is greater than or equal to 151 re[-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa?;or b.The design capacity is greater than or equal to 75 M'('472 061]but less than 151 ma[-950B01]and stores.a liquid with a maximum true vapor pressure greaterthan or equal tp 15.0 kPa but less than 27.6 kPa? c........ 40 CFR.Part 60,Subpart 0000/0000a.Standards of Performance for Crude Oil and Natural Gas Production.Transmission and Distribution 1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Continue-You have indicated the source category on the Proj 2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,50.2)between August 23,2011 and September 18,20157 Storage Tank is not subject NSPS 0000-Go to the next quest 3. Was this storage vessel constructed,reconstructed,car modified(see definitions 40 CFR,60.2)after September 18,2015P Go to the next question 4. Are potential VOC emissions'from the individual storage vessel greaterthan or equal to 6 tons per year? i Storage Tank is not subject N5P50000a. 5. Does this storage vessel meet the definition of"storage vessel" per 60.5430/60.5430a? 6. Is the storage Vessel subject to and controlled in accordance with requirements for storage vessels in40CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH7 [Note:If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to SOPS Oo0o/o00oa per 60.5365(e)(2)/60.5365a(e)(2)eves if potential VOC emissions drop below 6 tons per year] 40 CFR.Part 53,Subpart MACT HH,0i and Gas Production Facilities 1. Is the storage tank located at an od and natural gas production facility that meets either of the following criteria: GG. Continue-you have indicated the source category on the Prof e.A facility that processes,upgrades orstores hydrocarbon liquids'(63.750(5)(2));OR b.A facility that processes,upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user s(63.760(a)(3))? 2. Is the tank located at a facilitythat is major'for HAPs? FSAi=,';+'Sx Storage Tank is not subject MAR HH-There are no MACT HH 3. Doesthetank meet the definition of"'storage vessel"'in 63.7617 4. Does the tank meet the definition of'"s[orage vessel with the potential far flash emissions' per 63.7617 5. Is the tank subject to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 00007 :�:�'[y°;s sit _.s not Subpart A,General provisions per§63.764(a)Table 2 §63,765-Emissions Control Standards §63.773-Monitoring §65,774-Rear rdkeepimg §63.775-Reporting RACT Review RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area.R the tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing reputations,and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use ninon-mandatory language such as"recommend,""may,"`should" and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as'must"and°required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name PDC Energy,Inc. County AIRS ID 123 History File Edit Date 8/17/2020 Plant AIRS ID 9C1F Ozone Status Non-Attainment Facility Name Albrighton/Heidenreich 10 Sec Pad Author Diego Chimendes 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 1.1 1.1 0.0 0.0 36.9 728.6 0.3 67.0 21.5 1.1 1.1 0.0 0.0 15.2 _ 54.2 0.3 25.7 4.5 Previous Permitted Facility total 0.8 0.8 0.0 0.0 33.1 726.7 0.0 63.8 21.4 0.8 0.8 0.0 0.0 11.4 52.3 0.0 22.5 4.4 001 18WE0617 Four(4)300 bbl fixed roof condensate 0.0 5.0 0.1 0.2 0.0 0.3 0.1 0.0 No Change storage vessels 002 13WE3013.CN.XA Condensate Loadout 0.8 0.0 0.8 0.0 Cancellation received 06/01/18.Emissions are _ _ below APEN reporting thresholds. 003 13WE3014.CN.XA Fugitives 0.3 0.0 0.3 0.0 Cancellation received 08/11/16.Emissions are below APEN reporting thresholds. 004 GP02.CN SI RICE GM 5.7L,4SRB,87 HP(Site' 0:0 0:0 Cancellaftion received on 05/08/2020:equipment Rated),SN:10CHMM408070006 no longer exists as 0106/03/2019. 005 GP02.CN SI RICE GM 5.7L,4SRB,87 HP(Site 0.0 0.0 Cancellation request received on 02/06/2020. Rated),SN:10CHMM310300032 006 GP02.CN SI RICE Caterpillar G3306TA,4SRB,203 0.0 0.0 Cancellation received on 05/08/2020.Equipment HP,SN:O6X04440 no longer exists as of 02/03/2020 007 GP02.CN El RICE Caterpillar G3306TA,4SRB,203 0.0 0,0 Cancellation received on 05/08/2020.Equipment HP,SN:G6X00993 - no longer exists as of 09/22/2019 008 GP02.CN SI RICE.Red River GM 9.0L,4SRB,135 0.0 ,0.0. Cancellation received 12/12/1.8.Point no longer HP(site rated)SN:306656 exists. 009 18WE0618 Twelve(12)538 bbl fixed roof condensate 1.0 256.1 2.1 6.1 1.0 12.8 2.1 0.3 Point updated on 07/09/2020 DC 07/09/2020 storage vessels 010 GP07 Condensate Loadout 0.3 71.5 0.6 1.2 0.3 10.0 0.6 0.1 No Change 011 GP02 SI RICE GM Vortec 5.7L,4SRB,87 HP 0.1 0.1 11.8 0.6 9.2 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No Change _ (site rated),SN:13219099 012 GP02 CAT G30588 LE 690 hp 4SLB 0.3 0.3 3.3 9.9 19.8 2.3 0.3 0.3 3.3 4.7 6.7 1.7 No Change SN:RBK01132(ENG-6) 013 GP02 CAT G3058B LE 690 hp 4SLB 0.3 0.3 3.3 9.9 19.8 2.3 0.3 0.3 3.3 4.7 6.7 1.7 No Change SN:RBK01191(ENG-7) 014 GP02 RICE 4SRB GM M:Vortec 5.7L SN: 0.1 0.1 11.8 0.6 9.2 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No Change Z675140 XA External Combustion Sources 0.3 0.3 3.8 0.1 3.2 0.0 0.3 0.3 3.8 0.1 3.2 0.0 Insignificant Source XA Produced water tanks(TK-2(1)) 0.1 0.0 0.1 0.0 Insignificant Source XA Produced water tanks(TK-2(2)) 0.7 0.0 0.72 0.0 Insignificant Source FACILITY TOTAL 0.0 0.9 0.0 0.0 35.4 355.2 0.3 0.0 12.5 0.9 0.9 0.0 0.0 13.6 35.3 0.3 22.6 4.0 VOC: Syn Minor(NANSR and OP) NOx:Minor(NANSR and OP) CO: Minor(OP),Minor(PSD) HAPS: Minor 7777: Area Source Permitted Facility Total 0.6 0.6 0.0 0.0 31.5 353.5 0.0 60.8 12.4 0.6 0.6 0.0 0.0 9.8 33.6 0.0 19.4 3.9 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions -0.1 -0.1 0.0 0.0 -1.6 -18.7 0.0 -3.0 -0.4 Public Comment is required since operator is requesting federally enforceable limits to avoid other requirements(VOC<50 tpy).Modeling is _not required. Total VOC Facility Emissions(point and fugitive) 35.6 Facility is eligible for GP02 because CO<90 tpy and VOC/NOx<45 tpy. (A)Change in Total Permitted VOC emissions(point and fugitive) -18.7 Project emissions less than 25 tpy Note 1 Note 2 • 1 1239C1 F 8/17/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name PDC Energy,Inc. County AIRS ID 123 8/17/2020 Plant AIRS ID 9C1 F Facility Name Albrighton/Heidenreich 10 Sec Pad Emissions- uncontrolled (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tpY) 'Previous FACILITY TOTAL 4.0 0.4 0.3 1.4 1.2 0.1 0.4 13.5 0.1 0.1 0.0 0.0 21.5 001 18WE0617 Four(4)300 bbl fixed roof 39.0 78.0 2.0 10.0 264.0 13.0 0.2 condensate storage vessels 002 13WE3013.CN.XA Condensate Loadout 2.6 22.9 0.0 003 13WE3014.CN.XA Fugitives 14.0 14.0 13.6 13.7 15.7 0.0 004 GP02.CN SI RICE GM 5.7L,4SRB,87 HP(Site 0.0 Rated),SN: 10CHMM408070006 005 GP02.CN SI RICE GM 5.7L,4SRB,87 HP(Site 0.0 Rated),SN: 10CHMM310300032 006 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 203 HP,SN:G6X04440 007 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 203 HP,SN:G6X00993 008 GP02.CN SI RICE Red River GM 9.0L,4SRB, 0.0 135 HP(site rated)SN:306656 009 18WE0618 Twelve(12)538 bbl fixed roof 991.9 908.1 45.5 298.0 9919.7 95.2 6.1 condensate storage vessels 010 GP07 Condensate Loadout 252.2 2188.4 1.2 011 GP02 SI RICE GM Vortec 5.7L,4SRB,87 132.9 18.1 17.0 10.2 19.8 0.1 HP(site rated),SN: 13219099 012 GP02 CAT G3058B LE 690 hp 4SLB 3864.4 419.7 258.0 22.1 125.5 2.3 SN:RBK01132(ENG-6) 013 GP02 CAT G3058B LE 690 hp 4SLB 3864.4 419.7 258.0 22.1 125.5 2.3 SN:RBK01191 (ENG-7) 014 GP02 RICE 4SRB GM M:Vortec 5.7L SN: 132.9 18.1 17.0 10.2 19.8 0.1 Z675140 XA External Combustion Sources 0.0 XA Produced water tanks(TK-2(1)) 7.0 22.0 0.0 XA Produced water tanks(TK-2(2)) 12.6 8.0 0.3 1.7 12.6 0.0 TOTAL(tpy) 4.0 0.4 0.3 0.7 0.5 0.0 0.2 6.2 0.1 0.1 0.0 0.0 0.0 I *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text: uncontrolled emissions<de minimus Emissions with controls (lbs per year) POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL (tPY) 2 1239C1F 8/17/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT • AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name PDC Energy,Inc. County AIRS ID 123 8/17/2020 Plant AIRS ID 9C1F Facility Name Albrighton/Heidenreich 10 Sec Pad 'Previous FACILITY TOTAL 2.7 0.4 0.3 0.1 0.1 0.0 0.0 0.7 0.1 0.0 0.0 0.0 4.5 001 18WE0617 Four(4)300 bbl fixed roof 2.0 4.0 0.1 1.0 14.0 1.0 0.0 condensate storage vessels _ 002 13WE3013.CN.XA Condensate Loadout 2.6 22.9 - 0.0 003 13WE3014.CN.XA Fugitives 14.0 14.0 13.4 13.7 15.7 0.0 004 GP02.CN SI RICE GM 5.7L,4SRB,87 HP(Site 0.0 Rated),SN: 10CHMM408070006 005 GP02.CN SI RICE GM 5.7L,4SRB,87 HP(Site 0.0 Rated),SN: 10CHMM310300032 006 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 203 HP,SN:G6X04440 007 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 203 HP,SN:G6X00993 008 GP02.CN SI RICE Red River GM 9.0L,4SRB, 0.0 135 HP(site rated)SN:306656 009 18WE0618 Twelve(12)538 bbl fixed roof 49.6 45.4 2.3 14.9 496.0 4.£1 0.3 condensate storage vessels 010 GP07 Condensate Loadout 12.6 109.4 0.1 011 GP02 SI RICE GM Vortec 5.7L,4SRB,87 132.9 18.1 17.0 10.2 19.8 0.1 HP(site rated),SN: 13219099 012 GP02 CAT G3058B LE 690 hp 4SLB 2531.9 419.7 258.0 22.1 125.5 1.7 SN:RBK01132(ENG-6) 013 GP02 CAT G3058B LE 690 hp 4SLB 2532.0 419.7 258.0 22.1 125.5 1.7 SN:RBK01191 (ENG-7) 014 GP02 RICE 4SRB GM M:Vortec 5.7L SN: 132.9 18.1 17.0 10.2 19.8 0.1 Z675140 XA External Combustion Sources 0.0 XA Produced water tanks(TK-2(1)) 7.0 22.0 0.0 XA Produced water tanks(TK-2(2)) 12.6 8.0 0.3 1.7 12.6 0.0 TOTAL(tpy) 2.7 0.4 0.3 0.1 0.0 0.0 0.0 0.3 0.1 0.0 0.0 0.0 4.0 3 1239C1F 8/17/2020 Condensate Storage Tank(s) APEN Form APCD-205 CDPHE 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. 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: 18WE0618 AIRS ID Number: 123 / 9C1 F/009 Section 1 -Administrative Information Company Name': PDC Energy, Inc. Site Name: Albrighton/Heidenreich 10 Sec Pad Site Location Site Location: SESW Sec 10 T6N 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 'Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on alt 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. 431141 km COLORADO nyav== Permit Number: 18WE0618 AIRS ID Number: 123 /9C1 F/009 Section 2 - Requested Action O NEW permit OR newly-reported emission source ❑ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O 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- 0 MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name3 0 Change permit limit O 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 Et Notes: 2019 Actual throughput; updating existing Construction Permit Coverage; 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(2) For existing sources, operation began on: 1/9/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s) located at: 0 Exploration Et Production(E&P)site O Midstream or Downstream (non E&P)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? 0 Yes ❑ No If"yes", identify the stock tank gas-to-oil ratio: 0.0039 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) i 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 Q Yes ❑ No emissions≥6 ton/yr(per storage tank)? L O R D l.. - COLOR:DOXsllhbEnvHcnment Permit Number: 18WE0618 AIRS ID Number: 123 /9C1 F/009 Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) I Condensate Throughput: 205,601 246,721 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 45.8 degrees RVP of sales oil: 9.3 Tank design: 0 Fixed roof ❑ Internal floating roof 0 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 12 6,456 12/2017 1/2018 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 42498 Albrighton A-10HN 0 05 - 123 - 42499 Albrighton B-10HN 0 05 - 123 - 42493 Albrighton C-10HN 0 05 - 123 - 42500 Albrighton D-10HN 0 05 - 123 - 42501 Albrighton E-10HC 0 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. 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 (Latitude/Longitude or UTM) 40.496324/-104.54033 0 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) 0 Upward 0 Downward ❑Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) 0 Circular Interior stack diameter(inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): cvCOLORADO � _. 31OINIPIWOr.7.4":1=, Permit Number: 18WE0618 AIRS ID Number: 123 /9C1 F/009 [Leave btank unless APCD has already assigned a permit#and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: ❑ Recovery Unit(VRU): Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model: 4 x Cimarron 48"&lx 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: El Yes ❑ No Pilot Burner Rating: MMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: qo 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)? 23.7 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator 1 !!►► ',COLORADO Form APCD-205 Condensate Storage Tank(s)APED - Revision 12/2019 4 I MbtiO = „,=,,, Permit Number: 18WE0618 AIRS ID Number: 123 /9C1 F/009 [Leave blank unless APCD has already assigned a permit#and AIRS ID] 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? ID Yes ❑ No If yes, describe the control equipment AND 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) V0C Enclosed Combustors 100% 95% NOx CO HAPs Enclosed Combustors 100% 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: Requested Annual Permit Emission Factor? Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions8 Emissions . Emissions Basis MIS.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) VOC 2.0759 lb/bbl ProMax 213.40 10.67 256 08 12.80 NO,, 0.1380 lb/MMBtu TCEQ N/A 0.66 N/A 1.04 CO 0.2755 lb/MMBtu TCEO N/A 1.73 N/A 2.07 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. MIMIC Section 9 - Non-Criteria Pollutant Emissions Information . Does the emissions source have any uncontrolled actual emissions of non-criteria Yes O 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) Uncontrolled Units Basis (AP 42, Emissions Emissions8 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.0040 Iblbbl ProMax 82660 41.33 Toluene 108883 0.0037 lb/bbl ProMax 75675 37.84 Ethylbenzene 100414 0.0002 lb/bb ProMax 37.92(DM) 1.90(DM) Xylene 1330207 0.0012 Ib/bbl ProMax 248.30(DM) 12.41(DM) n-Hexane 110543 0.0402 lb/bbl ProMax 8.26640 413.32 2,2,4-Trimethylpentane 540841 0.0004 lb/bbl ProMax 79.29(DM) 3.96(DM) 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. 'COLORADO Form APCD-205 Condensate Storage Tank(s)APEN - Revision 12/2019 5 1 a�i=MT= Permit Number: 18WE0618 AIRS ID Number: 123 /9C1 F/009 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. 77 2 02 O Lure 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: 0 Draft permit prior to issuance El 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 air COLOR:DO ._ 6 I I*En. , E&P Storage Tank Air Pollutant Emissions Notice(APEN) Addendum Forml Company Name: PDC Energy,Inc. Source Name: Albrighton/Heidenreich 10 Sec Pad Emissions Source AIRS ID2: 123/9C1 F/009 Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05- 123-42503 Albrighton F-I0HN ❑ 05- 123-42497 Albrighton G-I0HN ❑ 05- 123-42494 Albrighton H-10HC ❑ 05- 123-42502 Albrighton I-10HN ❑ 05- 123-42496 Albrighton J-I0HN 0 05- 123-42495 Albrighton K-10HC ❑ 05- 123-42504 Albrighton L-I0HN ❑ 0 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A Form APCD-212 TK-1 (2)Addendum Hello