Loading...
HomeMy WebLinkAbout20193074.tiffa,t,„ COLORADO Department of Public Health b Environment Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 July 2, 2019 Dear Sir or Madam: RECEIVED JUL 08 2019 WELD COUNTY COMMISSIONERS On July 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Klein 19 Sec Pad 1; Josephine 19 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. Regards, /'1 Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director c -c, PLC ?P), .f -t ( 7T), Pw(rr/CH/£R/c.v ) C"7 It 7/19 Pub( i c Ri.v i ecc..) 0'7/ Q-1(19 2019-3074 a Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Klein 19 Sec Pad 1; Josephine 19 Sec HZ - Weld County Notice Period Begins: July 4, 2019 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: Klein 19 Sec Pad 1; Josephine 19 Sec HZ EEtP Well Pad SWNE Sec 19 T5N R64W Weld County The proposed project or activity is as follows: New EEtP well production facility located in the Ozone non - attainment area. Permitted equipment will include a condensate storage tank battery. Tanks service eleven newly drilled wells at an existing facility, along with two existing wells that were not previously associated with the facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) The 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 18WE1018 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: Ben Fischbach Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 eel COLORADO Department of Public Health ft Environment Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Ben Fischbach Package #: 387676 9 Received Date: 9/14/2018 Review Start Date: 1/28/2019 Section 01 - Facility Information Company Name: PDC Energy, Inc. County AIRS ID: 123 Quadrant Section Township Range SWNE 19 5N 64 Plant AIRS ID: Facility Name: Physical Address/Location: County: 9F2B Klein 19 Sec Pad 1; Josephine 19 Sec HZ SWNE quadrant of Section 19, Township SN, Range 64W 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? ❑ Carbon Monoxide (CO) O Particulate Matter (PM) O Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance it Self Cert Required? Action Engineering Remarks 017 Condensate Tank TK-1 (2) Yes 18WE1018 I Yes Permit Initial Issuance Section 03 - Description of Project Addition of new condensate tank battery to facility for storage of condensate from new wells. Section 04 - Public Comment Requirements Is Public Comment Required? Yes If yes, why? Greater than 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requiremen Was a quantitative modeling analysis required? No If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes, indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑ Title V Operating Permits (OP) ❑ O O O ❑ ❑ ❑ O Non -Attainment New Source Review (NANSR) O El Is this stationary source a major source? If yes, explain what programs and which pollutants her 5O2 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) NOx CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ O O ❑ ❑ ❑ ❑ ❑ 0 00 ❑ ❑ Condensate Storage Tank(s) Emissions Inventory Section 01 - Administrative Information Facility AIRS ID' 123 County 9F2B Plat 017 Point Section 02 - Equipment Description Details Detailed Emissions Unit One (1) 300 bbl and twenty (20) 528 bbl fixed roof condensate storage vessels connected via liquid manifold. Description: Emission Control Device VRU and Enclosed Flare Description: Requested Overall VOC & HAP Control Efficiency %: 96.75 % Section 03 - Processing Rate information for Emissions Estimates Primary Emissions - Storage Tank(s) Tanks are connected to a VRU with 35% uptime, 65% downtime. During VRU downtime, emissions routed to standard ECD with 95% destruction efficiency. Total (process 01 process 02) Actual Condensate Throughput = Requested Permit Limit Throughput = 806,720 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 004,720 Barrels (bbl) per year 806,720 Barrels (bbl) per year Requested Monthly Throughput = 68516 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = 968,064 Barrels (bbl) per year I Process 01 (emissions routed to VRU) Actual Condensate Throughput = Requested Permit Limit Throughput = 282,352 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 222,352 Barrels (bbl) per year 282,352 Barrels (bbl) per year Requested Monthly Throughput = 23981 Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = Requested Overall VOC & HAP Control Efficiency %: 332,122 Barrels (bbl) per year 100 % I Process 02 (emissions routed to Enclosed Flare) Actual Condensate Throughput = Requested Permit Limit Throughput = 524,368 Barrels (bbl) per year 524,368 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating Requested Monthly Throughput = 4453`., 524,112 Barrels (bbl) per year Barrels (bbl) per month Potential to Emit (PTE) Condensate Throughput = Requested Overall VOC & HAP Control Efficiency %: 629,242 Barrels (bbl) per year Secondary Emissions from Process 02 - Combustion Device(s) Heat content of waste gas Volume of waste gas emitted per BBL of liquids produced = 95 % 2586 Btu/scf 30.53 scf/bbl I Actual heat content of waste gas routed to control devices (VRU or Flare) = Requested heat content of waste gas routed to control devices (VRU or Flare) = Potential to Emit (PTE) heat content of waste gas routed to control devices (VRU or Flare) = Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Actual heat content of waste gas routed to combustion device via traditional calculation= Requested heat content of waste gas routed to combustion device via traditional calculation= Potential to Emit (PTE) heat content of waste gas routed to combustion device via traditional calculation= Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Process 01 (to VRU) Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 2.90 0.00 Sit* Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) teS• ' cE.F.(ir -1•-s Rash Benzene 0.006 0.00 Toluene 0.008 0.00 Ethylbenzene 0.000 1 0.00 Xylene 0.003 0.00 n -Hexane 0.058 D.00 224TMP 0.000 0.00 ,—........-.4:„,,.:a dr 5: 7w it ,.Z / r".r / ,,,; r. t",, N' t / /i / �o r• i• - .,y rr. .{vy / l J r. .A i-: 'sIrY'..yr/.y'Y'�W'3:t__t Process 02 (to Enclosed Flare) Emission Factors Condensate Tank Emission Factor Source Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) VOC 2.9001 0.1450 Site Specific E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific F -F. (includes flash) Site Specific E.F. (Includes flash) Site Specific E.F. (includes flash) Site Specific E.F. (Includes flash) Site Specific E.F. (includes flash) Benzene 6.22E-03 3.11E-04 Toluene 8.18E-03 4.09E-04 Ethylbenzene 2.30E-04 1.15E -0S Xylene 3.01E-03 1.51E-04 n -Hexane 5.79E-02 2.89E-03 224 TMP 2.68E-04 1.34E-05 Pollutant Control Device Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) P M 10 0.0000 TNRCC Flare Emissions Guidance (NOx) TNRCC Flare Emissions Guidance (CC)) PM2.5 2.5 0.0000 NOx 0.1380 0.01175 CO 0.2755 0.02346 vas 68,705 MMBTU per year 68,705 MMBTU per year 82,446 MMBTU per year 44,658 MMBTU per year 44,658 MMBTU per year 53,590 MMBTU per year 'NOTE: Operator calculated flash gas differently than usual, see notes section for calculation. Operator's value is more conservative, so will proceed with their value. 'During VRU downtime (65%) emissions are routed to an enclosed flare. 41399 MMBTJ per year 41399 MMBTJ per year 49679 MMBTJ per year Operator values more conservative, so will use for permitting K:\PA\2018\18WE1018.CP1 Condensate Storage Tank(s) Emissions Inventory Section OS - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Monthly Limits Controlled (lbs/month) V0C PM10 PM2.5 NOx CO 1403.8 1169.8 38.0 1169.8 38.0 6458 0.0 0.0 0.1 0.0 0.1 14 0.0 0.0 0.1 0.0 0.1 _ 18 3.7 3.1 3.1 3.1 3.1 523 7.4 6.2 6.2 6.2 6.2 1045 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene 6026 5022 153 5022 163 7920 6600 215 6600 215 222 185 6 185 6 2918 2431 79 2431 7.:+ n -Hexane 56028 46690 1517 46690 1517 224 TMP 260 216 7 216 7 Section 06 - Regulatory SummarYAnalysis Regulation 3, Parts A, B Source requires a permit Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII.C-F Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Storage Tank Is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? NO If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo O5 -O1. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Operator method for calculating annual flash gas: Flash Gas (MMBTU/yr) = (Uncontrolled VOC (ton/yr))•(20001b/ton)•(1/GasMW)•(379.41scf Gas/Ibmol)•(1/VOC%)•(Heat Content (BTU/scf))'(MMBtu/10^6 Btu) From ProMax: Unconotrolled VOC = 1169.8 tons/yr Gas MW = 45.877 lb/lbmol VOC% = 0.67306 Heat Content = 2586 Btu/scf Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # 001 SCC Code 4.04-003-11 Flied Roof Tank, Condensate_ working+Ixeatsting'flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condersate throughput PM2.5 0.00 0 lb/1,000 gallons condersate throughput NOx 0.28 0 lb/1,000 gallons condersate throughput VOC 69.1 97 lb/1,000 gallons condersate throughput CO 0.56 0 lb/1,000 gallons condersate throughput Benzene 0.15 97 lb/1,000 gallons condersate throughput Toluene 0.19 97 lb/1,000 gallons condersate throughput Ethylbenzene 0.01 97 lb/1,000 gallons condersate throughput Xylene 0.07 97 Ib/1,000 gallons condersate throughput n -Hexane 1.38 97 Ib/1,000 gallons condersate throughput 224 TMP 0.01 97 Ib/1,000 gallons condersate throughput 3 of 6 K:\PA\2018\18WE1018.CP1 Condensate Tank Regulatory Analysis Worksheet a Source s in the Non-Anainmant Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1..)? 2. Is the construction date (service date) prior to 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)? 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B. Section 11.0.3)? You have indicated that source is in the Non -Attainment Area Yes '. NON -ATTAINMENT 1. Are urcontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1_a)? 2. Is the construction date (service date) prior to 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)? 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY a CO emissions greater than 10 TPY (Regulation 3, Part B. Section 11.0.2)? Source requires a permit No Yes 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/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? karate tank is subject to Regulation 7, Section XN.C•F Section XII.C1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XII.C.2 -Emission Estimation Procedures Section XN.D - Emissions Control Requirements Section XR.E - Monitoring Section XNS —Recordkeeping and Reporting Colorado Refutation 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/maintenance area? 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 actual emissions greater than a equal to 2 tors per year VOC? Storage Tank is not subject to Regulation 7, Section XII-G Section XH.G.2 - Emissions Control Requirements Section XN.C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage Section XN.C2 - Emission Estimation Procedures Colorado Reesdatlon 7. Section XVQ 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 production facility', natural gas compressor station' a natural gas processing plant? 3. Is thiscondersate storage tank a fixed roof storage tar*? 4. Are uncontrolled actual emission` of this storage tank equal to or greater than 6 tons per year VOC? Storage tank is subject to Regulation 7, Section?Ml, N, Cl & C.3 Section XVILN — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVILC1 - Emissions Control and Monitoring Provisions Section XVILC3 - Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized' liquids? `Sterne tank is subject to Regulation 7, Section XVII.C2 Section XVILC2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR. Part 60, Subpart Kb. Standards of Performance for Volatle Onank linuid Storm Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m') ("472 Ms], 2. Does the storage vessel meet the following exemption in 60.111b(dX4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 m' 1-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 60.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23. 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.11lb? S. Does the storage vessel store a 'volatile organic liquid (VOL)"' as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ("29.7 mil and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 m' (-950 BBL) and stores a liquid with a maximum true vapor pressure" less than 33 kPa (60.1100(b))?; or c. The design capacity Is greater than a equal to 75 M3 r472 BBL) but less than 151 m' (-950 881) and stores a liquid with a maximum true vapor pressure less than 15.0 kPa(60.110b(b))? Yes Yes Yes NA... No Yes Vt' Yes NA tall NA:. NA Storage Tank s not subject to NSPS Kb Subpart A. General Provisions §60.112b - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.1156 - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 OR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility in the ashore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, recastructed, or modified (see definitions 40 OR. 60.2) between August 23.2011 and September It 2015? 3. Are potential VOC emissions' horn the individual storage vessel greater than or equal to 6 tons per year? 4. Does this condensate storage vessel meet the definition of "storage vessel"' per 605430? S. Is the store vessel subject to and eon n trolled 1 accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH 7 Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §603395 - Emissions Control Standards for VOC §603413 - Testing and Procedures §603395(g) - Notification, Reporting and Recordkeeping Requirements §603416(4 - Cover and Closed Vent System Monitoring Requirements §603417 - Control Device Monitoring Requirements [Note:: H a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the appicablity determination date, k should remain subject to NSPS 0000 per 60.5365(ex2) even if potential VOC emissions drop below 6 tons per year) 40 CFR. Part 63. Subpart MACT HH. OR and Gas Production Facilities 1. Is the storage tare located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR 2. 3. 4. S. b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delvered to a final end user' (63.760(a)(3))? Is the tank located at a facility that is major' for NAPS? Does the tank meet the definition of "storage vessel"' in 63.761? Does the tar* meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? Is the tank subject to control requirements under 40 CPR Part 60, Subpart Kb or Subpart 0000? (Storage Tank is not subject to MACT MS Subpart A. General provisions per §63.764 (a) Table 2 563.766 - Emissions Control Standards §63.773 - Monitoring 563.774 -Recordkeeping 563.775 - Reporting PACT Review MCI review is required if Regulation 7 does not apply AND If the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements. Diseiskner This document assists operators with determining applicability of certain requirements of the Clean Air Act. its implementing regulations, and Air Quality Donttol 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 arcumstances This document does not change or substitute for any law. regulation. a any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of the document and the language of the Clean Au Act,, its implementing regulaborts. and Air Quality Control Commission regulations. the language d the statute or regulation will control. The use of non -mandatory language such as 'rernrnmend.' -may. -'should, - and 'can.' is intended to descnbe APCD interpretatrans and recanmenctabons Mandatary terminology such as 'must' and 'required- we intended to descnbe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regtlatians. but this document does not establish legally binding regiiremen is in and of itself Yes No NA NA NA Yes NA NA NA Source Requires an APEN. Go to the next question Go to next question Source Requires a permit Continue - You have indicated the site attainment status on the project summary sheet. Continue - You have indicated the facility type on the project summary sheet. Source is subject Continue - You have determined facility attainment status on the Project Summary sheet Storage Tank is not subject to Regulation 7, Section XII.G - You have indicated facility type on project sun Continue - You have indicated the source category on the Project Summary sheet Go to the next question - You have indicated facility type on project summary sheet Go to the next question Source is subject to parts of Regulation 7, Sections XVII.B&C Go to the next question Source is subject to all provisions of Regulation 7, Section XVII, Subsections B & C Go to the next question Storage Tank is not subject NSPS Kb. Continue - You have Indicated the source category on the Project Summary sheet. Storage Tank Is not subject NSPS 0000 - This tank was carstructec outside of the applicability dates. Continue - You have indicated the source category on the Project 5urnmary sheet Storage Tank is not subject MACT HH - There are no MACT HH requirements for tanks at area sources COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name PDC Energy, Inc. County AIRS ID 123 Plant AIRS ID 9F2B Facility Name Klein 19 Sec Pad 1; Josephine 19 Sec HZ History File Edit Date 1/29/2019 Ozone Status Non -Attainment EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year) POIN T AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs PM10 PM2.5 H2S SO2 NOx VOC Fug VOC CO Total HAPs REMARKS Previous FACILITY TOTAL 0.4 0.4 0.0 0.0 58.4 1,232.0 0.2 54.0 33.8 0.4 0.4 0.0 0.0 10.2 77.6 0.2 17.1 2.4 Points 001-003 & 006-009 included in previous total. Previous Permitted Facility total O3 0.3 0 0 0 0 56.5 1,232.0 0 0 52 4 33.8 O3 0.3 0 0 0 0 8 2 77.6 0 0 15 5 2.4 Points 001-003 & 006-009 included in total ,previous 001 17WE0552 Sixteen (16) 538 bbl fixed roof condensate storage 2.1 527.1 4.3 14.9 2.1 26.4 4.3 0.7 Mod 002 GP05.CN Six (6) 400 bbl and two (2) 210 bbl fixed roof produced water storage vessels 0.5 0.1 0.5 0.1 Cancellation received 09/14/2018. Emissions are below APEN reporting thresholds 003 GP07 Condensate Truck Loadout 0.6 156.4 1.3 2.7 0.6 10.0 1.3 0.1 Mod 004 GP02.CN RICE - GM Vortec 5.7L 4SRB 88HP (SN: 10CHMM503060071) 0.0 0.0 Point Cancelled - Cancellation request received 10/31/2017. Source no longer exists at the facility. 005 GP02.CN RICE - GM Vortec 5.7L 4SRB 88HP (SN: 0.0 _ 0.0 Cancellation received 08/30/18. Source no longer exists at the facility. 006 GP02 RICE - GM Vortec 5.7L 4SRB 88HP (SN 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.8 0.6 1 7 01 No change 007 GP02.CN RICE - Red River GM 9.0L 4SRB 136HP (SN: 306432) 0.0 0.0 Cancellation received 09/26/18. Source no longer exists at the facility 008 GP02 RICE - GM Vortec 5.7L 4SRB 88HP (SN. 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.8 0.6 1.7 0.1 No change 009 GP02 SI RICE GM Vortec 5.7L, 4SRB, 88 HP, SN- 13219759 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No change - engine used for compression 010 18WE1013.XP SI RICE Cummins G5.9, 4SRB, 47 HP (site rated],_SN 0.0 0.0 5.9 1.0 3.2 0.1 0.0 0.0 0.5 0.3 0.9 0.1 Permit exempt - <50 HP engine (emissions based on APEN submitted 09/14/18) 011 18WE1014.XP SI RICE Cummins G5.9, 4SRB. 47 HP (site rated, SN: 0.0 0.0 5.9 1.0 3.2 0.1 0.0 0.0 0.5 0.3 0.9 0.1 Permit exempt - <50 HP engine (emissions based on APEN submitted 09/14/18) 012 18WE1015.XP SI RICE Cummins G5.9, 4SRB. 47 HP (site rated), SN 0.0 0.0 5.9 1.0 3.2 0.1 0.0 0.0 0.5 0.3 0.9 0.1 Permit exempt - <50 HP engine (emissions based on APEN submitted 09/14/18) 013 GP02 SI RICE Caterpillar G3306NA, 4SRB, 138 HP (site rated) SN: G6X07405 0.1 0.1 17.9 1.0 17.9 0.4 0.1 0.1 1.4 1.0 2.7 0.4 New source 014 GP02 SI RICE Caterpillar G3306NA, 4SRB, 138 HP (site rated) SN: G6 X07440 0.1 0.1 17.9 1.0 17.9 0.4 11 0.1 1.4 1.0 2.7 0.4 New source 015 GP02 SI RICE Caterpillar G3306NA, 4SRB, 138 HP (site rated) SN: R6S03469 0.1 0.1 17.9 1.0 17.9 0.4 0.1 0.1 1.4 1.0 2.7 0.4 New source 016 GP02 SI RICE Caterpillar G3406TA, 4SRB, 276 HP. SN: CRE00196 0.2 0.2 41.0 1.9 41.0 0.3 0.2 0.2 2.7 1.9 5.4 0.3 New source 017 18WE1018 One (1) 300 bbl and twenty (20) 538 bbl fixed roof rondensate storage vessels 3.1 1,169.8 6.2 30.6 3.1 38.0 6.2 1.0 New source 018 GP02 SI RICE Red River GM 9.0L, 4SRB, 136 HP (site rated) SN: 306651 0.1 0.1 16.0 3.5 14.6 0.2 0.1 0.1 0.7 0.9 0.5 0.2 New Source - engine used for electric generation XA External Combustion Sources 0.5 0.5 0.0 6.1 0.2 5.1 0.0 0.5 0.5 0.0 6.1 0.2 5.1 0.0 Insignificant Source XA Fugitives _ 0.5 0.1 0.5 0.1 Insignificant Source XA Produced Water Tanks (TK-2 (2)) 0.0 0.0 0.0 0.0 H Insignificant Source 0.0 0.0 FACIUTY TOTAL 1.3 1.3 0.0 0.0 175.9 1,867.3 0.5 163.7 50.4 1.3 1.3 0.0 0.0 23.5 83.6 0.5 38.7 4.1 VOC: Syn Minor (NANSR and OP) NOx: Syn Minor (NANSR and OP) CO: Syn Minor (OP) HAPS: Syn Minor n -Hex & Total HH: Not applicable - Area source 7777: Area Source Permitted FaalRy Total 0 8 0.8 0 0 0 0 152 1 1,8636 0 0 149 0 50 1 0 8 0 8 0 0 0 0 16 0 82 0 0 0 30 9 3 8 Excludes ands exempt from permds/APENs (A) Change in Permitted Emissions D 5 0 5 0 0 0 0 7 8 4 a 0 0 75 4 Pubcom will be required when the points in red are reviewed b/c new synthetic minor limits are being established. However. the current application only includes a new GPO? application. This does not require PC. Modeling is not required based on A change Note 1 Total VOC Facility Emissions (point and fugitiv A) Change in Total Permitted VOC emissions (point and fugitivE 84 1 _Project Facility is eligible for GP02 because < 90 tpy emissions less than 25 tpy 4 4 Note 2 Page 5 of 6 Printed 6/26/2019 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY - HAPs Company Name PDC Energy. Inc. County AIRS ID 123 Plant AIRS ID 9F28 Facility Name Klein 19 Sec Pad 1 Josephine 19 Sec HZ Emissions - uncontrolled (Ibs tier year POIN- PERMIT Description Fa"mkfe'yo. A°4"1"'r°• Acrolein Benzene Toluene EthNbeneene Xylenes n -Hexane McOH :14 TMP H2S TDTAL iron (Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0552 Sixteen (16) 538 bbl fixed roof condensate storage vessels 3014 3167 104 1327 21922 201 14.9 002 GP05.CN —jelly_ Six (6) 400 bbl and two (2) 210 bbl fixed roof produced stern* assets 32.0 41 4 1 •t 17 1 29.0 0.1 003 GP07 Condensate Truck Loadout 551.4 4784.7 2.7 004 GP02.CN RICE - GM Vortec 5.7L 4SRB SSH P (SN: 1 OCHMM5030600711 0.0 005 GP02.CN RICE - GM Vortec 5.7L 4SRB 88H (SN: 1 OCHMM310300018) 0.0 006 GP02 RICE - GM Vortec 5.7L 4SRB 88H (SN: 10CHMM405270014) ' . 1 n 20 0.1 007 GP02.CN RICE - Red River GM 9.0L 4SRB 136HP (SN 0.0 008 GP02 RICE - GM Vortex 5.7L4SRB 88HP(SN . tOCHMM50713(412) 134 18 17 10 20 0.1 009 GP02 SI RICE GM Vortec S.7L, 4SRB, 88 HP, SN. 133.6 18.2 17.1 10 3 19.9 0.1 010 1BWE1013.XP SI RICE Cummins G5.9, 4SRB. 47 HP (site rated), SN. 73475682 77.6 10.6 10 li 11.6 0.1 011 18WE1014.XP SI RICE Cummins G5.9, 4SRB. 47 HP (site rated), SN 73570699 77.6 10.6 10 E 11.6 0.1 012 18WE1015.XF'1SI RICE Cummins G5.9. 4SRB, 47 HP (site rated), SN.. 73571 169 77.6 10.6 10 6 11.6 0.1 013 GP02 SI RICE Caterpillar G3306NA. 4SRB. 138 HP (site rated) SN 06X07405 720 29 27 17 32 0.4 014 GP02 SI RICE Caterpillar G3306NA, 4SRB, 138 HP (site rated) SN O6X07440 720 29 27 17 32 0.4 015 GP02 SI RICE Caterpillar G3306NA, 4SRB. 138 HP (site rated) SN. R6S03469 720 29 27 17 32 0.4 016 GP02 SI RICE Caterpillar G3406TA, 4SRB, 276 HP. SN CRE00196 368 50 47 28 55 0.3 017 18WE1018 One (1) 300 bbl and twenty (20) 538 bbl fixed roof condensate storage vessels 5022 6600 185 2431 46690 : 1n 30.6 018 GP02 SI RICE Rod River GM 9.OL, 4SRB, 136 HP (site rated) SN: 306653 :09 28 4 :t.:1 161 31 : 0.2 XA External Combustion Sources 0.0 XA Fugitives 2O7 20 7 :0 1 20.3 23 4 0.1 XA Produced Water Tanks (TK-2 (2)) 8.9 11.6 0 .1 3.7 3.3 0.0 0.0 TOTAL (tpv) 1,7 0,1 0,1 4.4 4.9 0.2 1,9 36,7 0.1 0,2 0,0 0,0 50.4 'Total Reportable = all HAPs where uncontrolled emissions > de minimus values Rod Tort un ontro$c.d emissions < de mrnarus Emissions with controls (Ibs aer year POIN' PERMIT Description '' &I{ rVJ. "‘"•"'," Acrolein Benzene Toluene ) "'4''"i^h° Xylenes n -Hexane MeOH 22"-`1° H2S TOTAL Irvri Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 17WE0552 Sixteen (16) 538 bb( fixed roof condensate storage vessels 151 158 1-, 66 1096 10 0.7 002 GP05.CN Six (6) 400 bbl and two (2) 210 bbl fixed roof produced water stotaao vessels 32.0 41,4 1,4 1 ' 1 29 0 0.1 003 GP07 Condensate Truck Loadout 27.6 239.2 0.1 004 GP02.CN RICE - GM Vortec 5.7L 4SRB BBHP (SN: 10CH MM503060071) 0.0 005 GP02.CN RICE - GM Vortec 5.7L 4SRB 88H (SN: 10CHMM310300015) 0.0 006 GP02 RICE - GM Vortec 5.7L 4SRB 88HP (SN: 10CHMM405270014) ',4 18 1' 10 : o 0.1 007 GP02.CN RICE - Red River GM 9.01, 4SRB 136HP (SN' 0.0 008 GP02 RICE - GM Vortec 5.7i. 4SRB 8BHP (SN 10CHMM507130012) 134 18 17 10 :0 0.1 009 GP02 SI RICE GM Vortec 5.7L, 4SRB, 88 HP, SN• 133.6 18.2 17 1 10 3 19 9 0.1 010 18WE1013.XP SI RICE Cummins G5.9, 4SRB. 47 HP (site rated), SN. 73475682 77.6 10.6 10 6 11 6 0.1 011 18WE1014.XF1SI RICE Cummins G5.9, 4SRB, 47 HP (site rated), SN: 73570699 77.6 10.6 10 ri 11 6 0.1 012 18WE1015.XP'SI RICE Cummins G5.9, 4SRB. 47 HP (site rated), SN 73571169 77.6 10.6 10 6 11 6 0.1 013 GP02 SI RICE Caterpillar G3306NA, 4SRB. 138 HP (site rated) SN. G6X07405 718.6 29.1 27.4 16.5 31.9 0.4 014 GP02 SI RICE Caterpillar G3306NA, 4SRB. 138 HP (site rated) SN' O6X07440 718.6 29.1 27.4 16.5 31 9 0.4 015 GP02 SI RICE Caterpillar G3306NA. 4SRB, 138 HP (site rated) SN R6S03469 718.6 291 27.4 16.5 31.9 0.4 016 GP02 SI RICE Caterpillar G3406TA, 4SRB, 276 HP, SN CRE00196 368 SO 47 28 55 0.3 017 18WE1018 One (1) 300 bbl and twenty (20) 538 bbl fixed roof condensate storage vessels 163 215 6 79 1517 7 1.0 018 GP02 SI RICE Red River GM 9.OL, 4SRB, 136 HP (site rated) SN: 306653 209 .t 4 7N• e 16.1 31.2 0.2 XA External Combustion Sources 0.0 XA Fugitives _0 ;' 20.7 20.1 20.3 23.4 0.1 XA Produced Water Tanks (TK-2 (2)) 8 9 11 6 0.3 .1' 3 3 0.0 0.0 TOTAL (tpyl 1,7 0,1 0,1 0,3 0,2 0.0 0,1 1,5 0,1 0,0 0,0 0,0 4.1 b 18W11018 ( P1 6/26/2019 wrri:r€ Con; of Division artrint Hey: eth 8 environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 18WE1018 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Klein 19 Sec Pad 1; Josephine 19 Sec HZ 123/9F2B SWNE SEC 19 T5N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 (2) 017 One (1) 300 bbl and twenty (20) 538 bbl fixed roof storage vessels used to store condensate. Vessels are connected via liquid manifold. Emissions from the storage vessels are routed to a sales pipeline through the use of a vapor recovery unit (VRU). During VRU downtime, emissions are routed to enclosed combustor(s). The VRU has a maximum of 65% annual downtime. 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 COLORADO Air Pollution Control Division Page 1 of 10 1. Withi one iLindred atyd eighty days 80) of the latter of commencement of operation issuance of this permit, compliance with the conditions contained in this permit shall e demoijstrted,,to the Division. Itris the owner or operator's responsibility to self- ertify cor pliaocerwiti the-c-onditions 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.Qov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 3. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOx VOC CO TK-1 (2) 017 --- 3.1 38.0 6.2 Point Note: See "Notes to Permit Ho der" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. CDPME COLORADO Air Pollution Control Division Page 2 of 10 6. 1The 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 L.L.Lisubmit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to Ithe use of any other method of calculating emissions. 7. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipme nt ID AIRS Point Control Device Pollutants Controlled TK 1 (2) 017 Emissions from the storage vessels are routed to a sales pipeline through the use of a vapor recovery unit (VRU). During VRU downtime, emissions are routed to enclosed combustor(s). The VRU has a maximum of 65% annual downtime. VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 (2) 017 Total condensate throughput 806,720 barrels Condensate throughput during VRU downtime 524,368 barrels The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime shall be defined as times when emissions from the condensate storage vessels are routed to the enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total condensate throughput volume and total condensate throughput volume during VRU downtime shall be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly condensate throughput volume records, and the calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. COLORADO Air Pollution Control Division Page 3 of 10 STATEAND FERAIZ REGULATORREQUIREMENTS 10. :The py{q er�it number and ten digit FAIRS ID number assigned by the Division (e.g. 123/,4567J00`1�) shall b marked on e subject equipment for ease of identification. dgulatinn N m£ber 3;= ar`t`B-Section'II.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, Section XII. The operator shall comply with all applicable requirements of Section XII and, specifically, shall: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for condensate 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, Section XII.C.) (State only enforceable) 13. The combustion device covered by this permit is subject to Regulation Number 7, Section XVII.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section XVII, it shall be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, XVII.A.16; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto -igniter according to the following schedule: • All combustion devices installed on or after May 1, 2014, must be equipped with an operational auto -igniter upon installation of the combustion device; • All combustion devices installed before May 1, 2014, must be equipped with an operational auto -igniter by or before May 1, 2016, or after the next combustion device planned shutdown, whichever comes first. 14. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Section XVII.C.1. The owner or operator shall install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to May 1, 2014. The source shall follow the inspection requirements of Regulation Number 7, Section XVII.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING &t MAINTENANCE REQUIREMENTS COLORADO Air Pollution Control Division Page 4 of 10 16. Upon startuof these points; the eowner or operator shall follow the most recent perating and maintenance (O&tM) plan and record keeping format approved by the Division, order to demonstrate cornoliance on an ongoing basis with the requirements tf_sthis ,,per-mi ,Revvisi 1.0 -„the OW 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. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, Sections XVII.B.2. and XVII.A.16) Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NOX 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. COLORADO Air Pollution Control Division Page 5 of 10 20. —The quj e cents of Colorado Regulation No. 3, Part D shall apply at such time that any statiaarource nor' ,modification t becomes a major stationary source or major modification solely by ,virtule of a relaxation in any enforceable limitation that was established, after August 7--A 980 ron.,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 21. 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. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire permit and upon such occurrence, this permit shall be deemed denied ab initio. This permit may be revoked at any time prior to self -certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. CDPHE COLORADO Air Pollution Control Division Page 6 of 10 27. Violat'on�of ithe terms of a permit or of the provisions of the Colorado Air Pollution reventiofl'acid CoritrotkAct br the regulations of the AQCC may result in administrative, civil'or crimtpal enforcement actions under Sections 25-7-115 (enforcement), -121 (junctions) -122,(civi(penalties), 422.1 (criminal penalties), C.R.S. By: Ben Fischbach Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division Page 7 of 10 liA Notes Perrnit I-jgdor at �thetimeof this permit issuance: 1) The permit holder is required to! pay fees for the processing time for this permit. An invoice for these fees Al be issued after the permit is issued. The permit holder shall pay the invoice withfri30days ofrecerpt 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 shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 017 Benzene 71432 5,022 163 Toluene 108883 6,600 215 Ethylbenzene 100414 185 6 Xylenes 1330207 2,431 79 n -Hexane 110543 46,690 1,517 2,2,4- Trimethylpentane 540841 216 7 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. COLORADO Air Pollution Control Division Page 8 of 10 evels contained in this perit are based on the following emission factors: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors During VRU Downtime (lb/bbl) Controlled Emission Factors When Emissions are routed to the VRU (lb/bbl) Source NOx 0.01175 0.01175 0.0 TCEQ CO 0.02346 0.02346 0.0 VOC 2.9001 0.1450 0.0 ProMax 71432 Benzene 6.22E-3 3.11E-4 0.0 108883 Toluene 8.18E-3 4.09E-4 0.0 1330207 Xylene 3.01E-3 1.51E-4 0.0 110543 n -Hexane 5.79E-2 2.89E-3 0.0 Note: The controlled emissions factors for this point are based on a control efficiency of 100% when emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the enclosed combustor(s) during VRU downtime. The site specific emission factors for this source were developed using a site specific pressurized liquid sample in conjunction with ProMax. The pressurized liquid sample was obtained from the outlet of the HLP separators on 09/07/2018. The sample temperature and pressure are 118°F and 22.2 psig respectively. Uncontrolled actual VOC and HAP emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput. Controlled actual VOC and HAP emissions are calculated by multiplying uncontrolled emissions by a 100% control efficiency when emissions are routed to the VRU and a 95% control efficiency when emissions are routed to the enclosed combustor(s) during VRU downtime. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using permitted annual NOx and CO emissions (lb/yr) and condensate throughput (bbl/yr) during VRU downtime. Actual NOx and CO emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput during VRU downtime. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five- year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status COLORADO Air Pollution Control Division Page 9 of 10 perating Permit _ SynthOtic Mino„„� Source of: HOC, NOS, CO, Tai -Hexane, and Total HAPs vhANSR S.:‘ nthetic Minor�Source of: � „C;=_�Qx, CO,� MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-631199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division Page 10 of 10 SE 142018 Condensate Storage Tank(s) APEN e r„ CD Scattcn Y 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 loadings, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration lof 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: IgWE I01 AIRS ID Number: 123 /9F2B / Di 7 [Leave blank unless APCD has already assigned a permit n and AIRS ID) Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Klein 19 Sec Pad 1; Josephine 19 Sec HZ Site Location: SWNE Sec 19 T5N R64W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: 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 all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. COLORADO Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 1 Permit Number: AIRS ID Number: 123 i9F2B / [Leave L[ank unless APCD Has already assigned a permit d and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR - ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) OR - APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source Additional Info a Notes: Initial Construction Permit request for condensate storage tanks servicing eleven (11) newly drilled wells at an existing facility; Two (2) existing wells that were not previously associated with the facility have been commingled into this tank battery 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Storage Tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: Storage tank(s) located at: 24 6/18/2018 hours/day 7 days/week 0 Exploration Et Production (E&P) site 52 weeks/year ❑ Midstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? Yes No IS ■ Are Flash Emissions anticipated from these storage tanks? Yes No p ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No BI ■ If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. Yes No • p Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No • ■ Form APCD-205 - Condensate Storage Tank(si APEN - Revision 02/2017 ®� COLORADO 2 I �7L,_v=.;,, Permit Number: AIRS ID Number: 123 /9F2B / [Leave clank unless APCD has already assigned a permit and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl /year) Requested Annual Permit Limit4 (bbl /year) Condensate Throughput: 806,720 806,720 From what year is the actual annual amount? 2018 Average API gravity of sales oil: 51.4 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 8.7 ❑ External floating roof Storage Tank ID # of Liquid Manifold Storage Vessels in Storage Tank Total Volume of Storage Tank (bbl) Installation Date of Most Recent Storage Vessel in Storage Tank (month/year) Date of First Production (month/year) TK-1 (2) 21 11,060 7/31/2017 1/2001 Wells Serviced by this Storage Tank or Tank Battery5 (ECtP Sites On y) API Number Name of Well Newly Reported Well 05 - 123- 44679 Josephine 19M-234 O 05 - 123- 44682 Josephine 19M-334 ❑✓ 05 - 123- 44674 Josephine 19M-404 ❑✓ 05 - 123- 44676 Josephine 19N-204 ❑✓ 05 - 123- 44672 Josephine 19N-214 O 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.385396 / -104.592178 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Downward ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-2O5 - Condensate Storage Tank(s) APED - Revision 02/2017 3 I __ COLORADO 1'«n i 1 v'vc Permit Number: AIRS ID Number: 123 /9F2B / [Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: VOC and HAPs Vapor ❑✓ Recovery Unit (VRU): Size: Make/Model: EcoVapor Compressor Requested Control Efficiency: 33.25. 00 % - � 2/Z P J?� i hi t VRU Downtime or Bypassed (emissions vented): 65 ❑ Combustion r Device: Pollutants Controlled: VOC and HAPs Rating: MMBtu/hr 11 x Cimarron 48", 1 x Cimarron 60" Type: Enclosed Combustor Make/Model: Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: 95 98 % Waste Gas Heat Content: Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 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 (MP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 22.2 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator Form APCD-2O5 - Condensate Storage Tank(s) APEd - Revision 02/2017 4 COLORADO Permit Number: AIRS ID Number: 123 /9F2B / ll e blank artless APCD has already a__ fined a permit = and AIRS ID] Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Tank Vapor Recovery Unit (VRU) and Enclosed Combustor .9666.5b- 96. S10 NOx CO HAPs Tank Vapor Recovery Unit (VRU) and Enclosed Combustor 96€6%6-9 (.. "4- .74-10 Other: From what year is the following reported actual annual emissions data? 2018 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons! ear y ) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 2.9001 lb/bbl ProMax 1,169.80 39.8432.Q 1,169.80 39.8438.0 NOx 0.1380 Ib/MMBtu TCEQ N/A 47743.1 N/A -4r743.1 Co 0.2755 Ib/MMBtu TCEQ N/A 9.46.6), N/A 9,-46 6.1 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor& Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions7 (Pounds/year) Benzene 71432 0.0062 lb/bbl ProMax 5,021.51 169 I (53, Toluene 108883 0.0082 lb/bbl ProMax 6,600.05 .2-26r2-8 a IF Ethylbenzene 100414 0.0002 lb/bbl ProMax 185.21 (DM) 6,18 (DM). 6, Xylene 1330207 0.0030 lb/bbl ProMax 2,431.25 81.14- -3-q n -Hexane 110543 0.0579 lb/bbl ProMax 46,689.60 1-,-c-58.27 i S I t 2,2,4- Trimethylpentane 540841 0.0003 lb/bbl ProMax 216.45 (DM) 7.22 +QM-) 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 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. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 5 COLORADO [.,.,arms, ..l wog. Permit Number: AIRS ID Number: 123 /9F2B / [Leave bank unless APCD has already asst, ed a perml: a 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. Signature of Legally Authorized Person (not a vendor or consultant) / Date Jack Starr Air Quality Representative Name (print) Title Check the appropriate box to request a copy of the: ✓❑ Draft permit prior to issuance ❑✓ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 6 I COLORADO cry E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: PDC Energy, Inc. Source Name: Klein 19 Sec Pad 1; Josephine 19 Sec HZ Emissions Source AIRS ID2: 123 / 9F2B / Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 44678 Josephine 19N-314 VA 05 - 123 - 44673 Josephine 19N-334 11 05-123-44677 Josephine 19N-404 /1 05 - 123 - 44681 Josephine 19O-204 /1 05-123-44675 Josephine 19O-214 VA 05 - 123 - 44680 Josephine 19O-314 VI 05 - 123 - 20129 Seth 1 ❑ 05 - 123 - 24774 Seth 5 ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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