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Home My WebLink About20190921.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150 0 St PO Box 758 Greeley, CO 80632 February 22, 2019 Dear Sir or Madam: RECEIVED FEB 2 8 2010 WELD COUNTY COMMISSIONERS On February 28, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Sater 19J-203, 323; 19M243, 443 (pad 2). 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: Clara Gonzales Regards, 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 John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer vbl i s Pie\ Feu ) 3/Co/i f,C:PLC tc , HL Pt4C5Ml6RIClk ICK) 2/281nq 2019-0921 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Sater 19J-203, 323; 19M243, 443 (pad 2) - Weld County Notice Period Begins: February 28, 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: Sater 19J-203, 323; 19M243, 443 (pad 2) Well production facility NWNW SEC 19 T4N R63W Weld County The proposed project or activity is as follows: Controlled Condensate storage tank The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 16WE1073 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Timothy Sharp Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 !COLD RA DO. Ma.6IL,W bn st. Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Package if: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Sttrtr 1S� Physical Address/Locatio NWNW quadrant of Section 19, Township 4N, Range 63W, in Weld County, Colorado Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? on Monoxide (CO) 'Weld Section 02 - Emissions Units In Permit Application Quadrant Section Township Range iculate Matter (PM) [ne (NOx a VOC) AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering CondensateTarrff TK 1 0 EIEEE;; YeeE x ; , ,, r 1 WE1Q73 1 a\\ rttlit l tt a Ise\ rce ,00f2ii... ��xYCft\ i.,.�cerrnc�sr;:Li3o,15WE1t174 1 fiver..:..,/ ��Its��ta Ract req'd �2Cltp}r Unetld t ,.,3333111 ,� VAG 333 _h EE@EE1k;-• (''i:fliV 111 /%k/;.4„41 EE E3[ \k\' 111177 3 E 1131 J 311�;� '� ✓OE,„ / / 6,!„ 1� woo �1€;'Ei y �Cr`\R �� \ \ 1., 3j�,,�„i: .333313i,�F.\ s, >, .. ..:,,,,,, ,. ,:_r�?..�Si kF! i' �,; ,, ,,: .' .... ✓, ."S'a�("�X ��'��' \ r EYE �� E�•t..it. �.;. �E.:. 33�77 ... ,:'.ii 33:31ll11.1 ° ;,, ...: / ., tz '/ it//././, .. „„i.. � E 3 ...... .., ': ;, _:.. .... " /. „ems .. "_..\\�°�a33 ;:. ..., 313 1 . _ // � 3111 , :. .�1 )�33�� )) 1 HN 3ll31313133w3 :. %%/g 3) )) 33 1313333 y��` R•�\\o��3a`S �E[tEn fRS �3� i "'''/ 3331 f3 �7 711E '3 3U3333 ( lo//is/E 1133 31iAY� C E ,N \ .g ) N «< 111 //. /„ -,O1..CO M s ' :3o3EE111E. E Ee y / :_ :. r/f � .. �:� ,9/ - �:.. �.. 9% ,✓/%.' 111 Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? .Rec'#es'1 Section 05 - Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants hers 502 Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) VOC PM2.5 PM10 TSP HAPs B E❑❑ PM2.5 PM10 TSP HAPs O ❑ Condensate Storage Tank(s) Emissions Inventory Pollutant Section 01- Administrative Information Facility AlRs ID: County Plant Pon Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: Section 03- Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput= Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput Secondary Emissions - Combustion Device(s) Heat content of waste gas= I3I)=Btu/scf Volume of waste gas emitted per BBL of liquids produced = �) - iS � i, I scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Barrels (bbl) per year Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Actual Condensate Throughput While Emissions Controls Operating = 49,210 MMBTU per year 49,210 MMBTU per year 59,050 MMBTU per year Pollutant Uncontrolled Controlled (Ib/bbl) Ph/bbl) (Condensate Throughput) 0.051 0.50'...,'.. ., 0.005 (Condensate Throughput) Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (Ib/bbl) H. (Condensate Throughput) Emission Factor Souse Emission Factor Souse Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC 1004,7 837.2 41.9 837.2 41.9 - PM10 0.0 0.0 0,0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 NOx 4.1 3.4 3.4 3.4 3.4 CO 8.1 6.8 6.8 6.8 6.8 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (Ibs/year) (lbs/year) (Ibs/year) (Ibs/year) Benzene 3733 3111 156 3111 156 Toluene 3213 2678 134 2678 134 Ethyibenzene 184 153 0 153 0 Xylene 1408 1173 59 1173 59 n -Hexane 34486 28739 1437 28739 1437 224 IMP 306 255 13 255 13 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, B Not enough information Regulation 7, Section XII.C, D, E, F Storage Tank is not subject to Regulation 7, Sectiool<ll.C-F Regulation 7, Section Xll.G, C Storage Tank is not subject to Regulation 7, Sectionitil.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 NIPS Kb Regulation 6, Part A, NSPS Subpart OOOO Storage Tank is not subject to NSPS OOOO Regulation 8, Part E, MACr Subpart HH Storage Tank is not subject to MACT NH (See regulatory applicability worksheet for detailed analysis) Barrels (bbl) per year 3 of 6 K:\PA\2016\16WE1073.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons V0C 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 05-0 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 05-01. 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 Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 001 01 Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput N0x 0.63 0 Ib/1,000 gallons condensate throughput V0C 156.3 95 Ib/1,000 gallons condensate throughput CO - 1.27 0 lb/1,000 gallons condensate throughput Benzene 0.29 95 lb/1,000 gallons condensate throughput Toluene 0.25 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput Xylene 0.11 95 lb/1,000 gallons condensate throughput n -Hexane 2.68 95 lb/1,000 gallons condensate throughput 224 TMP 0.02 95 lb/1,000 gallons condensate throughput 4 of 6 K:\PA\2016\16W E1073.CP1xIsm Condensate Tank Regulatory Analysis Worksheet Colorado Re lotion 3 Parts A and B - APEN and Permit Requirements Sounx: i; in the Nonk/attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 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 facili uncontrolled VOC emissions greater than STAY, 0O0 greater than SOTPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.3)? You have indicated that source is in the Non.Attainmont Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the 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 from the greater than 2 TPY, 500 greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? Not enough information 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? 'Storage Tank is not subject to Regulation 7, Section KI1.C-P • 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 RILE — Monitoring Section XII.F —Recordkeeping 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/maintenance areal 2. Is this storage tank located eta 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 or equal to 2 tons per year VOC? Storage Tank is not subject to Regulation 7, Section MLR 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 ate 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' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual em ° of this storage tank equal to or greater than 6 tons per year VOC? IStorage tank is subject to Regulation 7, Section XVII, 0, C.1 A 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" liquids? 'Storage tank is subject to Regulation 7, Section 05/11.C.2 Section XVII.C.2 -'Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m) ("472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 ms ("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 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined In 60.1116? 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 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ma ["950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPe (60,110b(b))?; or c. The design capacity is greater than or equal to 75 M3 ["472 BBL] but less than 151 m' l'"950 BBL] and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60,110b(b))? Storage Tank is net subject to NSPS Kb Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60,1135 -Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations Yes Yes Yes No No Yes Continue-' Continue -' Storage Tar Continue-' Storage Tar Source is sr Continue-' Go to then Go to then Source Is st Storage Tar 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located at a facility In the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 4, Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels In 40 CFR Part 60 Sub art Kb or40 CFR Part 63 Subpart HH? Storage Tank is not subject no NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 660.5396 - Emissions Control Standards for VOC §60.5413 -Testing and Procedures 460.5395(g} - Notification, Reporting and Recordkeeping Requirements 460.5416(c) Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACY 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 criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR 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 delivered to a final end users (63.760(a)(3))? 2. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel"' in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Storage Tank is not suir)evt to MAC'i' H 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 tank meets both criteria, then review RACY requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document Is note rule or regulation, end the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," "may," should," and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as must"and "required" are intended to describe controlling requirements under the terns of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes NSW Tes Continue-' Storage Tar Storage Tar Go to then Source Is st Continue-' Storage Tar Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment CONSTRUCTION PERMIT 16WE1073 DRAFT Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Sater 19J-203, 323; 19M-243, 443 (Pad 2) 123/9EE8 NWNW SEC 19 T4N R63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 001 Eight (8) 400 barrel fixed roof storage vessels used to store condensate. Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section 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 shall 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/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) ,COLORADO Sir Pollution Control Division rL:u �x�e3 a or i ua tc Hee n v L.:vo+v' t Page 1 of 7 3. 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.) 4. 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.) 5. 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 6. 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 NO, VOC CO TK-1 001 --- 3.4 41.9 6.8 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for both criteria 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. 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 Equipment ID AIRS Point Control Device Pollutants Controlled TK-1 001 Enclosed Flare 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 ?COLORADO Air Pollution Control Division i !_„,st,,,x.. t or Pubitct feOth C, Enworkr.Y+t:t Page 2 of 7 TK-1 001 Condensate throughput 255,000 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. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. (Regulation Number 1, Section II.A.5.) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. 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. 13. 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. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Section XVII.C.2. OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING COLORADO Air Pollution Control Division rtrtent :..r t?ubt x t-rei;Etn b Ewirorrru nt Page 3 of 7 Initial Testing Requirements 16. 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 XII.C, XVII.B.2. and XVII.A.16) Periodic 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, on a weekly basis 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 XII.C, XVII.B.2. and XVII.A.16) ADDITIONAL REQUIREMENTS 18. 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 (NOr) 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. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the COLORADO Air, Pollution Control Division Deportment of Pubf heeler. Er•wirorenent Page 4 of 7 permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self -Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 22. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 23. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof 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. 24. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 25. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division ;r ra of lealth U Grtirorui[r,H Page 5 of 7 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 shall 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 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) 001 Benzene 71432 3111 156 Toluene 108883 2678 134 Ethylbenzene 100414 153 8 Xylenes 1330207 1173 59 n -Hexane 110543 28739 1437 2,2,4- Trimethylpentane 540841 255 13 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: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.1380 lb/MMbtu TCEQ CO 0.2755 lb/MMbtu TCEQ V0C 6.57 0.33 Source 71432 Benzene 0.012 0.001 Source 108883 Toluene 0.011 0.001 Source 1330207 Xylene 0.005 0.000 Source 110543 n -Hexane 0.113 0.006 Source 540841 2'2'4 Trimethylpentane 0.001 0.000 Source COLORADO Air Pollution Control Division 3zpart pent Pubii t t ieu€th ETIvis-Ortment Page 6 of 7 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 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. 6) 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. 7) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC PSD or NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) 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 I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division iA pfo3ne nt of PubfC Heu til 6 Lnviorr'. ;t Page 7 of 7 Permit Number: V1! l013 13 Facility Equipment ID: TK-1 Section 01— Administrative Information AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 Emission Source AIRS ID: 12,3 / aE Eg / OOt [Leave blank unless APCD has already assigned a permit # & AIRS ID] Company Name: PDC Energy, Inc. Source Name: Source Location: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization] Sater 19J-203, 323; 19M-243, 443 (Pad 2) NWNW Sec 19 T4N R63W Mailing Address: 1775 Sherman Street, Suite 3000 Denver, CO NAICS, or 1311 SIC Code: County: Weld Elevation: 4661 Feet ZIP Code: 80203 Person To Contact: Elizabeth Duncan Phone Number: (303) 860-5800 E-mail Address: Elizabeth.Duncan@pdce.com Fax Number: (303) 860-5838 Section 03 — General Information For existing sources, operation began on: This Storage Tank is ® Exploration & Production ❑ Midstream or Downstream Located at: (E&P) Site (Non-E&P) Site Will this equipment be operated in any NAAQS nonattainment area? ® Yes 0 No Is actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ® Yes 0 No ► Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 ► Are you requesting ≥ 6 ton/yr VOC emissions, or are uncontrolled actual emissions ≥ 6 ton/yr? General description of equipment purpose: Condensate Storage Tanks Section 04 — Storage Tank(s) Information Section 02 — Requested Action (Check applicable request boxes) ® Request for NEW INDIVIDUAL permit ❑ Request for coverage under GENERAL PE ❑ GP01 0 ❑ Request MODIFICATION to existing INDIVIIA:i eck boxes below) ❑ Change process or equipment ❑ Change c. ❑ Change permit limit ❑ Transfer of ow rs ip*] Other 0 0 Addl. Info. & Notes: APEN Submittal for Permit Exempt/Grandfathered source f APEN Submittal for update only (Please note blank APEN's will not be accepted) Initial permit request for new facility 7 / 5 / 2016 For new or reconstructed sources, the projected startup date is: Condensate Throughput: Requested Permit Limit: Actual: Average API Gravity of Sales Oil: Tank Design: Fixed Roof: 255,000 bbl/year 255,000 bbl/year 48.6 degrees Internal Floating Roof: Normal Hours of Source Operation: 24 hours/ 7 days/ day week Are Flash Emissions anticipated at these tanks ® Yes If "yes", identify the stock tank gas -to -oil ratio: series rules? If so, submit Form APCD-105. Actual While Controls Operational: 255,000 bbliyear RVP of Sales Oil 8.8 0 External Floating Roof: 0 Storage Tank ID TK-1 # of Liquid Manifold Storage Vessels in Storage Tank 8 Total Volume of Storage Tank (bbl) 3200 Installation Date of most recent storage vessel in storage tank (Month/Year) 3/2016 Date Of First Production (Month/Year) 7/2016 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-42066 Sater 19J-203 ►A 05-123-42065 Sater 19J-323 ►5 05-123-42062 Sater 19M-243 • 05-123-42060 Sater 19M-443 • - - • Yes Yes 52 weeks/ year ❑ No m3/liter ® No ❑ No Colorado Department of Public Health and Environment Air Pollution Control Division (APCD)This notice is valid for five (5) years. Submit a revised APEN prior to expiration of five-year term, or when a significant change is made (increase production, new equipment, change in fuel type, etc). Mail this form along with a check for $152.90 per APEN for non- E&P, midstream and downstream sources or $152.90 for up to five (5) APENs for E&P sources and $250 for each general permit registration to: - \ Colorado Department of Public Health & rpp en APCD-SS-B1 t� ED�V 4300 Cherry Creek Drive South LW .1100 Denver, CO 80246-1530 For guidance on how to complete this APEN fotXit: Air Pollution Control Division: (3Q3).692-3150 Small Business Assistance Program (SBAP): -(303) 692-3148 or (303) 692-3175 APEN forms: http://www.colorado.gov/cdphe/oilgasAPENS Application status: http://www.colorado.gov/cdphe/permitstatus FORM APCD-205 354101 Page 1 of 2 _ _ _ _ TK_l APEN -_ AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 Permit Number: Section 05 - Stack Information (For Midstream sites only) Operator Stack ID No. .. Stack Base Elevation (feet) Stack Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture. (%) Direction of stack outlet (check one): ❑ Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): 0 Circular: Inner Diameter (inches) = Section 07 — Control Device Information • Vapor Recovery Unit (VRU) used for control of the Storage Tank(s) Size: Make/Model: /1 Combustion Device used for control of the Storage Type: Enclosed Combustor Tanks) Make/Model 95 % Rating: MMBtu/hr 3 x Cimarron 48", 1 x Cimarron 60" Requested VOC & HAP Control Efficiency: % % VOC & HAP Control Efficiency: Requested: Minimum temp. to achieve requested control: Manufacturer Guaranteed: 98 % Annual time that VRU is bypassed (emissions vented): °F Waste gas heat content: Btu/scf ■ Closed loop system used for control of the storage tank(s) Description: Constant pilot light? .1 Yes ■ No Pilot burner rating: MMBtu/hr ■ Describe Any Other: Emission Source AIRS ID: Section 06 -Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM Horizontal Datum (NAD27, NAD83, WGS84) UTM Zone (12 or 13) UTM Fasting or ,,,UTM (meters or degrees) UTM Northing or Latitude (meters or degrees) Method of Collection for Location Data (e.g. map, GPS, GoogleEarth) WGS 84 -104.48827 40.30448 COGCC Website ❑ Horizontal 0 Down 0 Other: Length (inches) = ❑ Other (Describe): Width (inches) = Section 08 — Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 33 psig Please describe the separation process between the well and the storage tanks: High/Low Pressure Separator Section 09 — Emissions Inventory Information & Emission Control Information Emission Factor Documentation attached Data year for actual calendar yr. emissions below & throughput in Sec. 04 (e.g. 2007): 2016 Pollutant Emission Factor Actual Calendar Year Emission Requested Permitted Emissions Emission Factor Data Source Uncontrolled Basis Units Uncontrolled (Tons/Year) (Tons/Year) Tons/Year) Uncontrolled (Tons/Year) (Tons/Year) Tons/Year NOx 0.138 lb/MMBtu N/A 3.39 N/A 3.39 TCEQ VOC 6.5666 lb/bbl 837.24 41.86 837.24 41.86 ProMax CO 0.276 lb/MMBtu N/A 6.77 N/A 6.77 TCEQ Benzene 0.0122 lb/bbl 3108.82 lb/yr 155.44 lb/yr 3108.82 lb/yr 155.44 lb/yr ProMax Toluene 0.0105 lb/bbl 2687.70 lb/yr 134.38 lb/yr 2687.70 lb/yr 134.38 lb/yr ProMax Ethylbenzene 0.0006 lb/bbl 159.76 lb/yr (DM) 7.99 lb/yr (DM) 159.76 lb/yr (DM) 7.99 lb/yr (DM) ProMax Xylenes 0.0046 lb/bbl 1169.44 lb/yr 58.47 lb/yr 1169.44 lb/yr 58.47 lb/yr ProMax n -Hexane 0.1127 lb/bbl 28747.35 lb/yr 1437.37 lb/yr 28747.35 lb/yr 143737 lb/yr ProMax 2,2,4-Trimethylpentane 0.0010 lb/bbl 259.98 lb/yr 13.00 lb/yr 259.98 lb/yr 13.00 lb/yr ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to resort pollutants not listed above. Section 10 —Applicant Certification - I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. Elizabeth Duncan Signatte of Person Legally Authorized to Supply Data Date Name of Legally Authorized Person (Please print) 1 You will be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and needs to be resubmitted. 2 Annual emissions fees will be based on actual emissions reported here. If left blank, annual emissions fees will be based on requested emissions. ',.--- gl3O/26(4 Additional Information Required: Attach a pressurized pre -flash condensate extended liquids analysis, RVP & API analysis of the post -flash oil Attach E&P Tanks input & emission estimate documentation (or equivalent simulation report/test results) EHS Professional Title O Check box to request copy of draft permit prior to issuance. Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses O FORM APCD-205 Page 2 of 2 Check box to request copy of draft permit prior to public notice. ____TK-IAPEN_ Hello