Loading...
HomeMy WebLinkAbout20201594.tiff Cp,.��f_„ COLORADO �.,� +1! Department of Public COPHF Health b Environment Weld County - Clerk to the Board 1150 0 St PO Box 758 RECEIVED Greeley, CO 80632 April 21, 2020 APR 2 9 2020 WELD COUNTY COMMISSIONERS Dear Sir or Madam: On April 22, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC Energy, Inc. - Castle 29 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 &t Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator wpfC-) 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I / ∋ Jared Polis, Governor I Jill Hunsaker Ryan,MPH, Executive Director Pu b l:c Re v;e c,) cc:PL(irP)HL(1-K) PW(JM(ER/GH la ' 2020-1594 6/T/2-0 o&csKS 5/29/2o MrM9M Air Pollution Control Division '''''-r-41 c.M Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: PDC Energy, Inc. - Castle 29 sec HZ - Weld County Notice Period Begins: April 22, 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: Castle 29 sec HZ production facility NENW, Section 29, T5N, R64W Weld County The proposed project or activity is as follows: operator seeks to permit condensate tanks 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 19WE0818 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.Rov/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: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 40,„ ._ COLORADO Deportment of Public 1 I r Health a Environment Condensate Tank Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Source is in the Non-Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(R Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0! 2. grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions grei You have indicated that source is in the Non-Attainment Area NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulat Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0! 2. grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greats Source requires a permit Colorado Regulation 7,Section XII.C-F 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/ma 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor sta 3. Is this storage tank located upstream of a natural gas processing plant? Storage tank is subject to Regulation 7,Section XII.C-F Section XII.C.1 -General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Section XII.D—Emissions Control Requirements Section XII.E—Monitoring Section XII.F—Record keeping and Reporting Colorado Regulation 7,Section XII.G 1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/ma 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actu 'Storage Tank is not subject to Regulation 7,Section XII.G Section XII.G.2-Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Colorado Regulation 7,Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well productic 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions4of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7,Section XVII, B,C.1&C.3 Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3- Recordkeeping Requirements 5. Does the condensate storage tank contain only"stabilized" liauids? 40 CFR, Part 60,Subpart OOOO/OOOOa,Standards of Performance for Crude Oil and Natural Gas Production,Tra Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, na 1. segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) betty 3. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after 4. Are potential VOC emissions)from the individual storage vessel greater than or equal to 6 tons per year? 5. Does this condensate storage vessel meet the definition of"storage vessel"2 per 60.5430/60.5430a? 6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR PE Storage Tank is not subject to NSPS O0OOa [Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions ab should remain subject to NSPS OOOO/OOOOa per 60.5365(e)(2)/60.5365a(e)(2)even if potential VOC emissib 40 CFR, Part 63,Subpart MACT HH,Oil and Gas Production Facilities 1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteri a. A facility that processes, upgrades or stores hydrocarbon liquids) (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enter b. delivered to a final end user2 (63.760(a)(3))? 2. Is the tank located at a facility that is major3 for HAPs? 3. Does the tank meet the definition of"storage vessel"4 in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"5 per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO? Storage Tank is not subject to MACT HH Subpart A, General provisions per§63.764(a)Table 2 §63.766- Emissions Control Standards §63.773- Monitoring §63.774- Recordkeeping §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. If the t Disclaimer This document assists operators with determining applicability of certain requirements of the Commission regulations. This document is not a rule or regulation, and the analysis it contair facts and circumstances. This document does not change or substitute for any law, regulatio, enforceable. In the event of any conflict between the language of this document and the lang Quality Control Commission regulations, the language of the statute or regulation will control. "may,""should,"and "can,"is intended to describe APCD interpretations and recommendatioi intended to describe controlling requirements under the terms of the Clean Air Act and Air Qi r®y. . COLORADO 440-411 Mr Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE0818 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: Castle 29 sec HZ Plant AIRS ID: 123 A07C Physical Location: NENW quadrant, section29, township 5 north, range 64 west County: Weld Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description TK-1 001 Eight 538 barrel condensate storage tanks Enclosed combustors This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after commencement of operation under this permit by submitting a Notice of Startup (NOS)form to the Division. The Notice of Startup (NOS) form may be downloaded online at https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit 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.) Page 1 of 9 a . COLORADO igo Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 3. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) F.4.) 4. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NOX VOC CO Type TK-1 001 0.0 2.1 23.1 4.1 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per year. Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year. The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 7. The owner or operator must use the emission factors found in "Notes to Permit Holder and/or Attachment X" to calculate emissions and show compliance with the limits. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 8. The 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.) Page 2 of 9 MGM• - COLORADO 4 Air Pollution Control Division CDFHE `" Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Equipment AIRS Control Device Pollutants ID Point Controlled TK-1 001 Enclosed combustor VOC and HAP PROCESS LIMITATIONS AND RECORDS 9. 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 Equipment AIRS Process Parameter Annual Limit ID Point TK-1 001 Condensate 214,743 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 10. 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.)I.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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) 13. The source is subject to Regulation Number 7, Part D, Section I.G. The operator must comply with all applicable requirements of Section I. 14. 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 Page 3 of 9 a . . COLORADO ' - Air Pollution Control Division CDPHE Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado 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. 15. 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. 16. 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. 17. The storage tanks covered by this permit are subject to the storage tank measurement system requirements of Regulation Number 7, Part D, Section II.C.4. 18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, 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 a MAINTENANCE REQUIREMENTS 19. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OI:tM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 20. The owner or operator must demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen-minute period during normal operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23) Page 4 of 9 tiM,M-CCOLORADO '14I , Air Pollution Control Division Department of Public Health b€nvironment Dedicated to protecting and improving the health and environment of the people of Colorado ADDITIONAL REQUIREMENTS 21. 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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 hak11 COLORADO map4ualkiti Air Pollution Control Division COPHE 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: Kirk Bear Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Page 6 of 9 _ COLORADO Air Pollution Control Division CDAHE Department of Public Health Er Environment Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 2255 113 Toluene 108883 2792 140 Ethylbenzene 100414 86 5 001 Xylenes 1330207 1053 53 n-Hexane 110543 20509 1026 224 TMP 540841 34 2 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 CAS # Pollutant Emission Factors Source lb/bbl NOx 0.1380 lb/MM Btu TCEQ CO 0.2755 lb/MM Btu TCEQ VOC 4.3027 promax Page 7 of 9 »gib• - COLORADO Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled CAS # Pollutant Emission Factors Source lb/bbl 71432 Benzene 0.0105 promax 108883 Toluene 0.0130 promax 100414 Ethylbenzene 0.0004 promax 1330207 Xylene 0.0049 promax 110543 n-Hexane 0.0955 promax 540841 224 TMP 0.0002 promax 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, CO, NOx, HAP PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC, NOx 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 Page 8 of 9 C,.. .Ms'f.M- COLORADO 44"Y°41° Air Pollution Control Division CDPHE Department of Public Health b Environment Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 9 of 9 3 tog Condensate Storage Tank(s) APEN • ;., CDPHE CO Form APCD-205 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Qov/pacific/cdphe/air-permits. This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /9 WE g I g AIRS ID Number: I Z, 1Ay. 1C /CO I [Leave blank unless APCD has already assigned a permit ft and AIRS ID] Section 1 -Administrative Information Company Name': PDC Energy, Inc. Site Name: Castle 29 sec HZ Site Location Site Location: NENW Sec 29 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.coin 1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. Lit l(4LilC COLORADO Form APCD-205- Condensate Storage Tank(s)APEN- Revision 7/2018 1 I AV Noah=1st Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action 0 NEW permit OR newly-reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit 0 GP01 0 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 0 Change company name3 O Change permit limit 0 Transfer of ownership' 0 Other(describe below) -OR ▪ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El 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: Initial permit request for condensate storage tanks at a new facility 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: 05/13/2019 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 Ft Production (EEO)site ❑ Midstream or Downstream (non EEtP)site Will this equipment be operated in any NAAQS nonattainment area? ✓❑ Yes 0 No Are Flash Emissions anticipated from these storage tanks? ❑r Yes ❑ No Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? p Yes 0 No If"yes", identify the stock tank gas-to-oil ratio: 0.008015 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 0 Yes 0 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 0Yes ❑ No emissions≥6 ton/yr(per storage tank)? wricoLoRAD0 Form APCD-205 - Condensate Storage Tank(s)APEN - Revision 7/2018 2 I AY 3°, Z,g, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Condensate Throughput: 178,952 214,743 From what year is the actual annual amount? Projected Average API gravity of sales oil: 50.5 degrees RVP of sales oil: 7.3 Tank design: ❑✓ Fixed roof O 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 8 4,304 4/2018 5/2019 Wells Serviced by this Storage Tank or Tank Battery6(EEP Sites Only) API Number Name of Well Newly Reported Well 05 -123 -46284 Castle 1N ✓❑ 05 -123 -46291 Castle 2N ✓❑ 05 -123 -46294 Castle 3N ❑✓ 05 - 123 -46292 Castle 4N 0 O 5 Requested values will become permit limitations. Requested limit(s)should consider future growth. 6 The El-tP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.37615 /-104.5761 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level (feet) (°F) (ACFM) (ft/sec) N/A Indicate the direction of the stack outlet: (check one) ❑Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size: (check one) ❑Circular Interior stack diameter(inches): 0 Square/rectangle Interior stack width(inches): Interior stack depth(inches): 0 Other(describe): COLORADO Form APCD-205-Condensate Storage Tank(s)APEN - Revision 7/2018 3 ""° "`°'�°nta;12,0 nmvn Permit Number: AIRS ID Number: [Leave blank 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 ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC and HAPs MMBtu/hr l 4 x Cimarron 48" & 1 x Cimarron 60" Enclosed Combustors Make/Mode: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Constant Pilot Light: 0 Yes D No Pilot Burner Rating: Waste Gas Heat Content: 2,551 Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 - Gas/Liquids Separation Technology Information (ECtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 28.9 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 COLORADO 4 , I ; en of PuL.k HealhF6nVltonln✓nl Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency(%reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency (%reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled Basis e Units (AP-42, Emissions Emissions8 Emissions Emissions Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) VOC 4.3027 lb/bbl ProMax 384.99 19.25 461.99 23.10 NOx 0.1380 Ib/MMBtu TCEQ N/A 1.71 N/A 2.05 CO 0.2755 Ib/MMBtu TCEQ N/A 3.42 N/A 4.10 Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions8 Number Basis Mfg.etc) Pounds/ ear g (Pounds/year)) (Pounds/year) Benzene 71432 0.0105 lb/bbl ProMax 1,872.90 93.65 Toluene 108883 0.0130 lb/bbl ProMax 2,329.54 116.48 Ethylbenzene 100414 0.0004 lb/bbl ProMax 70.92(DM) 3.55(DM) Xylene 1330207 0.0049 lb/bbl ProMax 873.58 43.68 n-Hexane 110543 0.0955 lb/bbl ProMax 17,087.90 854.40 2,2,4- 540841 1 .54E-04 lb/bbl ProMax 27.64 (DM) 1 .38 (DM) Trimethylpentane 5 Requested values will become permit limitations. Requested timit(s)should consider future growth. 7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. w COLORADO Form APCD-205- Condensate Storage Tank(s)APEN - Revision 7/2018 5 I • 'v HOaI 7.6[nWnvuy¢ril Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. If this is a registration for coverage under General Permit 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. Uat@ Sign:t re of Legally Authorized Person (not a vendor or consultant) Jack Starr Air Quality Representative Name(print) Title Check the appropriate box to request a copy of the: ❑✓ 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 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver, CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd my COLORADO Form APCD-205 - Condensate Storage Tank(s)APEN - Revision 7/2018 6 I ^`°:"`°"`NpxtlhtF•i onrtien� Hello