The URL can be used to link to this page

Browse Search

Home My WebLink About20180083.tiffCOLORADO Department of Public Health ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150OSt PO Box 758 Greeley, CO 80632 December 19, 2017 Dear Sir or Madam: RECEIVED DEC 2 7 2017 WELD COUNTY COMMISSIONERS On December 21, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. — Cockroft 19 Section Pad. 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 & 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 Rib C Vi2.t,t.) cc.:PLC(run(TP),H1.CITT), ((�� PwCSAvCH13MlCkl 1 13/IS' iataerI7 2018-0083 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. — Cockroft 19 Section Pad — Weld County Notice Period Begins: December 21, 2017 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: Cockroft 19 Section Pad oil and gas SENE, Section 19, T5N, R63W Weld County The proposed project or activity is as follows: request a permit for an oil and gas well site 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 17WE0042 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. Any such comment must be submitted in writing to the following addressee: Kirk Bear Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health £r Environment. CONSTRUCTION PERMIT 17WE0042 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: Description: PDC Energy, Inc. Cockroft 19 Sec Pad 123 9F07 SENE, Section 19, T5N, R63W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LOAD -1 001 Truck loadout of condensate by submerged fill 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.qov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 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 COLORADO .Air Pollution Control Division Page 1 of 8 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 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. (Reference: 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 LOAD -1 001 -- -- 6.0 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 6. 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 LOAD -1 001 Enclosed Flare VOC and HAPs PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation Number 3, Part B, II.A.4) Process/Consumption Limits COLORADO I Mr Pollution Control Division Page 2 of 8 Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD -1 001 Condensate 1,016,600 barrels The owner or operator shall calculate 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. 8. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation Number 3, Part B, III.E. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d orXVIl.B.1.c shall have no visible emissions. (Reference: Regulation Number 1, Section II.A.1. & 4.) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill and emissions shall be controlled by a flare. (Reference: Regulation 3, Part B,1II.D.2) 12. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. 13. The owner or operator shall follow loading procedures that minimize the leakage of V0Cs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. The owner or operator shall inspect onsite loading equipment during loading operations to ensure that hoses, couplings, and valves are maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. The inspections shall occur at least quarterly. Each inspection shall be documented in a log available to the Division on request. b. All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. 14. The owner or operator shall: a. Install and operate the vapor collection and return equipment to collect vapors during loading of tank compartments of outbound transport trucks. COLORADO Pollution Control Division ;t 7? ia6Gv ideal ?e Ys ti 3=am. Page 3 of 8 b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back -pressure less than the pressure relief valve setting of transport vehicles. OPERATING & 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 your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30"' whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted. 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 ICOLORADO Air Pollution Control Division Pu64 r 1ies 1 Ee;v'ironrn r,E Page 4 of 8 • 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 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. COLORADO i Mr Pollution Control Division epamne't d Pu€ k I ieai ,?° rsetvirznme4t: Page 5 of 8 By: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance.1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division G°S`rrz m-- f Putrft i th , t^tfironment Page 6 of 8 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 I I. 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 (Ib/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 417 21 n -Hexane 110543 3660 183 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (Ib/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: Pollutant CAS # Uncontrolled Emission Factors (lb/bbl) Source NOx 0.138 lb/MM Btu TCEQ CO 0.276 lb/MM Btu TCEQ VOC 0.236 CDPHE Benzene 71432 0.00041 CDPHE n -Hexane 110543 0.0036 CDPHE Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of 100% 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 facility is classified as follows: COLORADO Air Pollution Control Division Fartiner!t of 3vW,: Page 7 of 8 Applicable Requirement Status Operating Permit Synthetic Minor source of VOC, HAP NANSR Synthetic Minor source of VOC, HAP 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 777Z — Subpart MMMMM MACT 63.8980 -End Subpart NNNNN — Subpart XXXXXX OLORADO Pollution Control Division , Enwt,nr e t Page 8of8 Colorado Air Permitting Project Project Details Review Engineer: Package It: Received Date: Review Start Date: Section 01- Facility Information Company Name: PDC Energy, Inc. County AIRS ID: 123 Plant AIRS ID: 9F07 , Facility Name: Cocktail 19 Sec Pad Physical Address/Location: SENE quadrant of Section 19, Township 5N, Range 63W W, in Weld County, Colorado 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? ECarbon Monoxide (CO) Particulate Matter (PM) done (NOx & VOC) Kirk gear 357143 1/9/2017 11/13/2017 Weld Quadrant Section Township Range SENE 9 63W Section 02 - Emissions Units In Permit Application AIRS Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Hydrocarbon -Liquid Loading LOAD -1 Yes 17WE0043 Yes Permit Initial Issuance 002 Condensate Tank TK-1 Yes 17WE0043 1 Yes Permit 9 sitial Issuance Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Yes Greater than 25 tons per year in Non -Attainment Area Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? No If yes, for what pollutants?;gym If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Colorado Air Permitting Project 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 here: Prevention of Significant Deterioration (PSD). Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP HAPs O O ❑ 0 ❑OOO:1O O 00 ❑ O ❑ SO2 NOx CO VOC PM2.5. PM10 TSP HAPs OOOOOO OOOOOO OO ❑" Condensate Storage Tank(s) Emissions Inventory Pollutant Section al- Administrative Information Facility Allis ID: County Plant Pain Section 02- Equipment Desttiption 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 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = Bartels (bbl) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= 1, s. ;Btu/scF Volume of waste'gas emitted per BBL of liquids produced= :';i 1-?'-scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 0 MMBTU per year 0 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = - 0 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Condensate Tank Uncontrolled Controlled (lb/bbl) (Ib/bbl) (Condensate Throughput) ,0.3a20 (Condensate Throughput) 0070135 0.000140 0.000146 0.000010 0.000065 0.001215 0.000010 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat Combusted) 0b/bbl) K (Condensate Throughput) 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source 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 713.0 713.0 35.6 713.0 35.6 PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0,0 0.0 0.0 0.0 NO8 0.0 0.0 0.0 0.0 0.0 CO 0.0 0.0 0.0 0.0 0.0 Potential to Emit Actual Emissions Requested Permit Umits: Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled -Controlled (lbs/year) (lbs/year) (Ibs/year) (lbs/year) (lbs/year) Benzene 2846 2846 142 2846 142 Toluene. 2948 - 2948 147 2948 147 Ethylbenzene 203 203' 10 203 10 Xylene 1322 1322 66 1322 66 n -Hexane 24703 24703 1235 24703 1235 224 TRAP 203 203 10 203 10 Section 06- Regulatory Summary Analysis Regulation. 3,, Parts A, R Source requires a permit Regulation 7, Section XILC, D, E, F Storage tank is subject to Regulation 7, Section XII.C-1 Regulation 7, Section XII.G, C Storage Tank is not subjectto Regulation 7, Section Xi1.G Regulation 7, Section XVII.B,.C.1, C.3 Storage tank is subjectto Regulation 7, Section XVII, B, Cl & C.3 Regulation 7, Section XVII.C2 Storage tank is subject to Regulation 7, Section XVILC2 Regulation 6, Part A, NIPS Subpart Kb Storage Tank is not subject to NSPS Kb. Regulation 6, Part A,. NIPS Subpart 0000 Storage Tank is not subjectto NSPS 0000 Regulation 8, Part E, MACr5ubpart HH Storage Tank is not subject to MACr HH (See regulatory applicability worksheetfor detailed analysis) Barrels (bbl) per year 3 of33 K:\PA\2017\ 17WE0042.CP1.xism 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 VOC per year? er 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 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? fiYa7 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 88 - Technical Analysis Notes Section 09 - Inventor/ SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 002 01 as 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 NOx 0.00 0 lb/1,000 gallons condensate throughput VOC 33.4 95 lb/1,000 gallons condensate throughput CO 0.00 0 lb/1,000 gallons condensate throughput Benzene 0.07 95 lb/1,000 gallons condensate throughput Toluene 0.07 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.03 95 lb/1,000 gallons condensate throughput n -Hexane 0.58 95 lb/1,000 gallons condensate throughput 224TMP 0.00 95 1b/1,000 gallons condensate throughput 4 of 33 K:\PA\2017\17WE0042.CP1.xlsm Condensate Tank Regulatory Analysts Worksheet condo RegutaBgn 3 Parts A gild 1-APEN and be rnAt Requirements You brave indicated thassource is in iho Non.Atta€ ntent Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section llD.l.a)? Y. 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 addldohal guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOO greater than lO TPY or CO emissions greater than OOTPY (Regulation 3, Part 8, Section 11.0.3)? 'You have indicated that source is in the Non.AttrLnrent Area • NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this Individual source greater than 1TPy (Regulation3, Part A, Section Il.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 0501 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 2TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 'Source requires apermit 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 all and gas exploration and production operatient, natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? (Storage tank Fs subjecttp Regulation 7, Sectivn 111.1-P Section XILC.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section Xll.C.2—Emission Estimation Procedures Section XII.D—Emissions Control Requirements Section Xll.E—Monitoring Section XII.F—Recordkeeping and Reporting Colorado Regulation 7. Section XII.G • 1. Is this storage tank located In the a -hr ozone control area or any ozonon-attainment area or attainment/maintenance area? 2. Is this storage tank located at natural gas processing plant? 3. Does this storage tank exhibit "Flash"(e.g.storing non.stablllzed liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? 'Storage -Tank it not eub[oct to Regulnenn'I, Section Ally Section )01.6.2 -Emissions Control Requirements Section XII.C.1 -General Requirements forAlr Pollution Control Equipment -Prevention of Leakage Section XII.C.2-Emission Estimation Procedures Colorado Regulation J. Section XVII 1. ule this tank located at a transmission/storage facility? 2. Is -this condensate storage tank° located at an all 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 emissions° of this storage tank equal to or greater than 6 tons per year VOL? Source Requires an APEN. Go to the next question Go to next question Source Requires a permit .as 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 Y°'.F iiiSource is subject . Yes vv''ldrv'Kr. Yes WOE 'Storage tank is subjeceon Regu€atinn 7, Section XV:i, B, C.1 &C.3 Section 10/11.1 -General Provisions for Air Pollution Control Equipment and PfeVenfion of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeepiog Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? 'Storage tank is subjecttu Regulation 7, 100110n X111.1.0 Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 90 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')1-97? BBIs)? 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 m'I'10,000 BBL] used for petroleum' or condensate stored,processed, or treated prior to custody transfer' as defined In 60.113b? 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after -July 23, 1984? 4. ones the tank meet the definition of "storage vessel"' in 60.1111? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111h? 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 1-29.7 psi] sod without emissions to the atmosphere (60.110h(d)(2))7; or b. The design' capacity is greater than or equal to 151 m' ("950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110b(h))?; or c. The design capacity Is greater than or equal to 75 M1("472 BBL] but less than 151 ms [-950 BBL] and stares a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))? Storage Tank is not ruble 4 to NIPS Kb Subpart A, General Provisions §6a.112b -Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b- Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performancefor crude oil and Natural Gas Production.Transmission and Distribution 1. Is this condensate storagevessel located at a facility in the onshore oil and natural gas production segment natural gas processing segment or natural Bas transmission and storage segment of the Industry? 2. Was this Condensate storage vessel constructed,reconstructed, or modified (see definitions 4016R,60.2) between August 23, 2011 and September 18, 2015? 3. Are potential VOC emission?P from the individual storage vessel greater than or equal to b tons per year? 4, Does thiscondensate storage vessel meet the definition of"storage vessel"' per 60.5430? 5. Is the storage vesselsubject to and controlled in accordance with requirements for storage vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HO? 'Storage Tank is notsubiav 4.a MPS 0000 Subpart A, General Provisions per 460:5425 Table 3 §60.5393 - Emissions Control Standards for VOC 460.0413 -Testing and Procedures 460.5355(g) - Notification, Reporting and Recordkeepiog Requirements 500.5416(c) - Cover and Closed Vent System Monitoring Requirements 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 summary sheet. Source is subject 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 neat question Source is subjectto all provisions of Regulation 7, Sections B & C Storage Tank Is not subject NIPS Kb -The storage vessel capacity is below the applicable threshold. Storage Tank Is not subject NIPS Kb, Continue - You have indicated the source category on the Project Summary sheet. Go to the next question Storage Tank Is not subject MPS 0000. 160.5417 —Control Device Monitoring Requirements [Ndte:. If astorage vessel is previously determined to he subject to NIPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.53611e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACTHH, Oil and Gas Production Facilities 1.-Isthe storage tank located at an oil and natural gas production facility that meets eitherofthefollowing criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2(); OR b. Afacility that proce se; upgrades or [ re 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))7 2. Is the tank located at a facility that major'. for HAPs7 3. Does the tankmeet the definition of "storage vessel"° in 63.7617 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"! per 63.7617 5 Is the tank subject to controlrequirements under 40 CFR Part 60, Subpart Kb or Subpart 00007 !Storage Tank in not raDject to tv3ACP liii Subpart A, General provisions per 563.764 (a) Table 2 §63.766 -Emissions Control Standards §63.773- Monitoring 663.774- Recordkeeping §63.775: Reporting - -PACT Review YES RACY review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. It the tank meets both criteria, then review RACT requirements. Definitions for Drop Dawn Lists Yes No NA Continue - Y u have. Indicated the source categoryon the Project Summary sheet. Storage Tank Is not subject MACTHH- There are no MACTHH requirements for tanks at area sources Crude Oil Storage Tank(s) Emissions Inventory Section 01- Administrative Information Facility AIRS ID: County Plant Point 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 Throughput= Requested Permit Limit Throughput= Potential to Emit (PTE) Throughput = arrels (bbl) per year rrels (661) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= ) ; ;Btu/scf Volume of waste gas emitted per BBL of liqui produced = m ar,:, scf/bbl Actual heat content of waste vs 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 = Section 04 - Emissions Factors& Methodologies Will this storage tank emit flash emissions? Actual Crude Oil Throughput While Emissions Controls Operating = 0 MMBTU per year 0 MMBTU per year 0 MMBTU per year Pollutant Pollutant Uncontrolled Controlled (lb/bbl) (Ib/bbp (Crude Oil Throughput) (Crude Oil Throughput) 0.00 0.000 0.000 0.000 0.000 0.000 0.000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (waste heat combusted) (Ib/bhl) (Crude Oil Throughput) 0.0000 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source 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 PM10 PM2.5 NOx CO 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual missions Uncontrolled Controlled Ohs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylhenzene Xylene n -Hexane 224TMP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Section 06- Regulatory Summary Analysis Regulation 3, Parts A,B Regulation 7, Section XVII.B, C1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, N5PS Subpart 0000 Regulation 8, Part E, MACE Subpart HH (See regulatory applicability worksheet for d Not enough information Not enough information Not enough information Not enough information Not enough information Not enough information etailed analysis) 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 20 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 14-03 'MIME 7 of 33 K:\PA\2017\17 W E0042. CP1xls m Crude Oil Storage Tank(s) Emissions Inventory 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 of crude oil drawn at the facility being permitted? If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95% for a flare or combustion device? fives, 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 ta- Technical Analysis Notes Section 09 - Inventory5CC Coding and Emissions Factors AIRS Point # 0 Process # 01 Definitions for Drop Down Lists Storage Tank Emissions Factor Options Crude Oil State E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific EPA TANKS ER Working and Breathing Only Other (Documented in Technical Analysis Notes) Qualifiers No Yes Not applicable - stabilized tank Control Devices Enclosed Flare Open Rare Vapor Recovery Unit (VRU) Control Device Combustion Emissions Factor Options NOx CO PM AP -42 Chapter 13.5 lndustri AP -42 Chapter 13.5 AP -42 Table 1.4-2 (PM10/PM.2.5) TNRCC Flare Emissions Guid TNRCC Flare Emissit Other- Explain AP -42 Table 1.4-1(NOx( AP -42 Table 1.4.1 (CO) Other- Explain Other- Explain SCC Codes - Storage Tank Emissions 4.04-003-12 Fixed Roof Tank, Crude Oil, working+breathing+flashing losses 4-04-003-02 Fixed Roof Tank: Working & Breathing Losses 4-05-003-22 External Floating Roof Tank, Crude Oil, working+breathing+flashing 4-04-003-06 External Floating Roof Tank: Working and Breathing Losses 4-04-003-32 Internal Floating Roof Tank, Crude Oil, working+breathing+flashing 4-04-003-07 Internal Floating Roof Tank: Working and Breathing Losses SCC Codes - Flaring Combustion Emissions 3-10-001-60 Flares Uncontrolled Emissions Pollutant Factor Control% Units PM10 #DIV/0! 0 lb/1,000 gallons crude oil throughput PM2.5 #DIV/0! 0 lb/1,000 gallons crude oil throughput NOx #DIV/01 0 lb/1,000 gallons crude oil throughput VOC 0.0 0 lb/1,000 gallons crude oil throughput CO #DIV/01 0 lb/1,000 gallons crude st throughput Benzene 0.00 0 lb/1,000 gallons crude oil throughput Toluene 0.00 0 lb/1,000 gallons crude oil throughput Ethylbenzene 0.00. 0 lb/1,000 gallons crude oil throughput Xylene 0.00 0 Ib/1,000 gallons crude oil throughput n -Hexane 0.00 - 0 lb/1,000 gallons crude oil throughput 224 TAW 0.00 0 lb/1,000 gallons crude oil throughput 8 of 33 K:\PA\2017\17W E0042.CP1.xlsm Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Re ulation 3 Parts A and B - APEN and Permit Requirements iYou have indicated that source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather.applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? 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 II.D.3)? 'you have Indicated that source is in the Non -Attainment Area NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? No 'Not enough information Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? Yes INot enough information 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 crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. Not enough information 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 (m5) [-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"3 In 60.1116? 5, Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 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 ms ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 M3 ["472 BBL] but less than 151 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11ob(b))? Not enough Information Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC §60.113b -Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60,116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this crude oil 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 crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? Continue - ` Continue - ontinue - ` 3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"' per 60.5430? Not enough Information Subpart A, General Provisions per §60.5425 Table 3 §60.6396 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(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 OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities 2. 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 liquids2 (53.760(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))? 1. 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 OOOO7 INot enough information Subpart A, General provisions per §63.764 (a) Table 2 §63.766- Emissiohs 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 RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing 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 tennis of the Clean Air Aot and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes ontinue - Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative information Facility AIRs ID: 331 County Plan Poin 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 Produced Water Throughput= Requested Permit Umit Throughput = Potential to Emit (PTE) Produced Water Throughput = Barrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating = Barrels (661) per year Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= tr:,1 Btu/scf Volume of waste gas emitted per BBL of liquids produced ?":;'R'yj; ': I P1;1 scf/bbl Actual heat content of waste gas routed to combustion device= Requested heat content of waste gas routed to combustion device = 0 MMBTU per year 0 MMBTU per year Potential t& Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? IMMEMIEMI Pollutant Pollutant Produced Water Tank Uncontrolled Controlled (lb/bbl) (lb/bbl) (Produced Water Throughput) (Produced Water Throughput) 0.00 0.000 0.000 0.000 0.000 0.000 0.000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (113/bbl) (waste heat combusted) 1.=232MMMEZE MI (Produced Water Throughput) 0.0000 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source Section 05- Emissions Inventory Criteria Pollutants I Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC 0.0 0.0 0.0 0.0 0.0 PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 NOx 0.0 0.0 0.0 0.0 0.0 CO 0.0 0.0 0.0 0.0 0.0 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) fibs/year) (lbs/year) (lbs/year) Benzene 0 0 0 0 0 Toluene 0 0 0 0 0 Ethylbenzene 0 - 0 0 0 0 Xylene 0 0 0' 0 0 n -Hexane 0 0 0 0 0 224TMP 0 0 0 0 0 Regulation 3, Parts A, 0 Not enough information Regulation 7, Section XVII.B; C.1, C.3 Not enough information Regulation 7, Section XVIl.C2 Not enough information Regulation 6, Part A, NSPS Subpart 0000 Not enough information (See regulatoryapplicabilityworksheet for detailed analysis) 11 of 33 K:\PA\2017\ 17WE0042.CP1.xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements 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 water sample drawn at the facility being permitted and analyzed usingflash liberation analysis? 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. See PS Memo 14-03, Questions 5.9 and 5.12 for additional guidance on testing. 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 # 0 Process # SCC Code 01 4-04-003-15 Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions Pollutant Factor Control % Units PM10 #DIV/0l 0 lb/1,000 gallons liquid throughput PM2.5 #DIV/Di 0 lb/1,000 gallons liquid throughput NOx #DIV/01 0 lb/1,000 gallons liquid throughput VOC 0.0 0 lb/1,000 gallons liquid throughput CO #DIV/01 0 lb/1,000 gallons liquid throughput Benzene 0.00 0 lb/1,000 gallons liquid throughput Toluene 0.00 0 lb/1,000 gallons liquid throughput Ethylhenzene 0.00 0 lb/1,000 gallons liquid throughput Xylene 0.00 0 lb/1,000 gallons liquid throughput n-Hexaoe 0.00 0 lb/1,000 gallons liquid throughput 224 TMiP 0.00 0 lb/1,000 gallons liquid throughput 12 of 33 K:\PA\2017\17WE0042.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements 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 operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 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 II.D.3)? 'You have indicated that source is in the Non -Attainment Area NON -ATTAINMENT _ 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? 'Not enough information Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions4of this storage tank equal to or greater than 6 tans per year VOC? 'Not enough information Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C,1 - Emissions Control and Monitoring Provisions Section)?VII.C.3 - Recordkeeping Requirements 5. Does the produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. INot enough information Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water 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 produced water 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 produced water storage vessel meet the definition of "storage vessel"' per 60.5430? [Not enough information Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for V0C §60.5413 - Testing and Procedures §60.5395(8) - Notification, Reporting and Recordkeeping Requirements §60.5416(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] 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 RACT requirements. Disclaimer MIEMI Yes ,\....r Y Yes Continue - Continue - Continue-` This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances, This document does not change or substitute for any law regulation, or any other legally binding requirement and is not legally enforceable. In, the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations; and Air Quality Control Commission regulations the language of the statute or regulation will control. The use ofnon-mandatory language such as "recommend," "may" "should," and 'can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "mus" and "required" are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Glycol Dehydrator Emissions Inventory Section 01 -Administrative Information 'Facility AIRS ID: County Plant Point Section 02- Equipment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number. Design Capacity: Recirculation Pump Information Number of Pumps Pump Type Make: Model: Design/Maz Recisculadon Rate: Dehydrator Equipment Flash Tank Reboller Sumer Stripping Gas Dehydrator Equipment Description Mscf/day One(1) natural gas dehydration unit (Make: , Model: , Serial Number:) with a design capacity of MMscf per day. This emissions unit Is equipped with (Make: , Model: ) driven glycol pump with a design capacity of gallons per minute. This dehydration unit Is equipped with a still vent. Emission Control Device Description: Emissions from the still vent are routed to the . As a secondary control device, still vent emissions are routed to the . Section 03- Processing Rate Information for Emissions Estimates Primary Emissions- Dehydrator Still Vent and Flash Tank (If present) Requested Permk Limit Throughput = _,;,,, az TMMscf per year Potential to Emit(PTE) Throughput = 0 MMscf per year Secondary Emisdons - Combustion Device(s) for Air Pollution Control Still Vent Control Condenser: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Still Vent Gas Fleeting Value: Still Vent Waste Gas Vent Rate: Flesh tank Control Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Rash Tank Waste Gas Vent Rate: Control Efficiency % hr/yr )E;iliggi ill'Rh ::`'`:"'':Y' P. Control Efficiency % 'scf scfh Control Efficiency% Wet Gas Processed: Still Vent Primary Control: 0.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 0.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Wet Gas Processed: Flash Tank Primary Control: 0.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 0.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Glycol Dehydrator Emissions Inventory section 04- Emissions Factors & Methodologies Dehydrator Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate STILL VENT Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (Ib/hrl Controlled (lb/hr) VOC 0 0 Benzene 0 0 Toluene 0 0 Ethylbenzene 0 0 Xylenes 0 n -Hexane 0 0 224-TMP ... 0 0 FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled (Ib/hrl' Controlled (lb/hr) Controlled (Ib/hr)- VOC NF. >ult3t`£ 0 0 Benzene , 3 il�i ) 3fIiVlllll%t MN" 0 0' Toluene /i33)) .__�......,,,,,, vu l;;i D 0 Ethylbenzene 0 0 0 Xylenes : ,Y=3 0 0 n -Hexane 1.� 0 0 224-TMP 0 0 Emission Facto VOC Pollutant Glycol Dehydrator Uncontrolled Controlled (Ib/MMscf( (Ib/MMscf) (Wet Gas Throughput) (Wet Gas Throughput) #OIV/01 RDIV/0! #Div/01 DIV/0! REIN/0! ODN/0! #OIV/01 DI V/01 #DIN/01 ODIV/OI #DIV/Ol 00N/o! #DIN/01 #ON/01 Benzene Toluene Ethylbenzene Xylene Hexane 224 TMP Pollutant Still Vent Primary Co I Device Emission Factor Source Uncontrolled (Ih/MMBtu( (Ib/MMsct) (Waste Heat Combusted) Uncontrolled (Waste Gas Combusted( PM10 PM2.5 000 CO 0.0000 0.0000 0.0000 0.0000 Pollutant Flash Tank Primary Con I Device Pollutant Flash Tank Secondary Control Device Pollutant still Vent Secondary Control Device Uncontrolled (Ib/MM Btu) Uncontrolled (Ib/MMBtu) Uncontrolled (Ib/MMsct) Uncontrolled (Ib/MMscf) Uncontrolled )lh/MMBtu) (lb/MMscr) (Waste Heat Combusted) Uncontrolled (Waste Gas Combusted) PM10 PM2.5 Not CO 0.0000 0.0000 0.0000 0,0000 Section OS - Emissions Inventory Did operator request'a buffer? Requested Buffer(%): Emission Factor Source Emission Factor Source Emission Factor Source Emission Factor Source 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) PM10 PM2.5 Nox CO VOC 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0,0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year( Requested Permit Limits Uncontrolled Controlled fibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Glycol Dehydrator Emissions Inventory Section 06- Regulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section XVII.R,o Regulation 7, Section XVII.8.2.e Regulation 7, Section XII.H Regulation e, Part E, MACT Subpart HH (Ares) Regulation 8, Part E, MACT Subpart HH (Major) Regulation 8, ParfE, MACT Subpart HHH (Sea regulatory applicability worksheet for detailed analysis) Not enough information Nat enough information Not enough information Not enough information Nat enough information Not enough information You have Indicated that this facility Is not subject to MAR HHH. Section 07- Initial and Periodic Sampling and Testing Requirements Was the emended wetgas sample used in the GlyCalc model/Process model site -specific and collected within a year of application submittal? lino, the permit will contain an 'Initial Compliance" testing requirement to demonstrate compliance with emission llimits Does the company request a control device efficiency greater than 95% for a flare or combustion device? 9F _ If yes, the permitwill contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on Inlet and outlet concentration sampling Section 09- Investor/ SCC Coding and Emissions Factors AIRS Point # Process # 01 SCC Code Uncontrolled Pollutant Emissions Factor Control % Units PM10 \0010/01 0.0% b/MMscf PM2.5 #DIV/01 0.0% h/MMscf NOB #010/01 0.0% b/MMscf VOC #01V/01 #DIV/01 b/MMscf CO #01V/01 0.0% b/MMscf Benzene #010/01 #015/01 b/MMscf Toluene #131V/01 #DIV/01 b/MMscf Ethylbenzene #OIV/01 #010/01 b/MMscf Xylene #OIV/01 #DIV/0I b/MMscf n -Hexane #DIV/0! #DIV/01 b/MMscf 224 IMP #DIV/01 #DIV/01 b/MMscf Dehydrator Colorado Regul ATTAINMENT 1. Are uncont 2. Are total fa NON-ATTAINM 1. Are uncont 2. Are total fa Colorado Regul 1: Is this glycc 2. Is this glycc 3. Is the sum 4. Are actual t Section XII. MACT Ana IN 1. Is the dehyi a. b. 2. Is the dehyi 40 CFR, Part 63 Area Sourc 1. Is the dehyl Exemption! 2a. 2b. 3. Is the unit I Major Sour 1. Does the fa Small or La 2a. 2b. Small Dehv 3. 4. 40 CFR. Part 63 1 Is the facilit Small or La 2a. 2b. Small Dehv 3. 4. Colorado Regul 1. Is the dehyi 2. Is this dehy 3. Is this deh 4. Was this gl) 4a. 5. If construct Section XVI Section XVI Alternative 6. Regulatory Analysis Worksheet ation 3 Parts A and B - APEN and Permit Requirements You have indicated that source is in the Non -Attainment Area rolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Pa cility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TF You have indicated that source is in the Non -Attainment Area ENT rolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, S cility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater thi Not enough information ation 7, Section XII.H natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/r natural gas dehydrator located at an oil and gas exploration and production operation', natural gas compressor Df actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Re 'Not enough information — Emission Reductions from glycol natural gas dehydrators ISIS drator located at an oil and natural gas production facility that meets either of the following criteria: A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user2 (63.760(a)(3))? drator located at a facility that is a major source for HAPs? Not enough information Subpart MACT HH, Oil and Gas Production Facilities e Requirements drator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))? s Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per d Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere. ocated inside of a UA plus offset and UC boundary area? Not enough information Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring Standards §63.774 - Recordkeeping §63.775 - Reporting •ce Requirements icility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility- rge Dehv Determination Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per d Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere Requirements Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation; INot enough information Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting Subpart MACT HHH, Natural Gas Transmission and Storage Facilities :y wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the rge Dehv Determination Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per d Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere Requirements Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicabl You have indicated that this facility is not subject to MACT HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284 Recordkeeping §63.1285 - Reporting ation 7, Section XVII.D drator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)? drator located at a transmission/storage facility? ydrator located at an oil and gas exploration and production operation , natural gas compressor station ycol naturalgas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? equal to or greater than 6 tons per year VOC or 2 tpy VOC if the dehydratoris located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)? .ed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to INot enough information II.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions II.D.3 - Emissions Reduction Provisions Emissions Control (Optional Section) Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary Not enough information Section XVII.B.2.e - Alternative emissions control equipment Disclaimer Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing 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 Yes Yes Yes Continue - You have indicated the attainment status on the Project Summary Sheet. Continue - You have indicated the facility type on the Project Summary Sheet. Continue - Source is subject to MACT HH requirements. You have indicated the source category on t Continue - You have previously indicated this in the beginning of the MACT section Continue - You have previously indicated this in the Reg 7, Section XII determination he Project Summary Sheet. Hydrocarbon Loadout Emissions Inbentory Section 01 -Administrative Information 'Facility AIRS ID: x. is lllJlll j12,r4,,,1=,; �a 5007 County Plant Section 02- Equipment Description Detail Detailed Emissions Unit Description:• Emission Control Device Description Ismb loadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency %: Section 03 -Processing Rate Information for Emissions Estimates Primary Emissions - Hydrocarbon Loadout Actual Volume Loaded = Requested Permit Limit Throughput= Potential to Emit (PIE) Volume Loaded= Poi Barrel. (bbl) per year Actual Volume Loaded While Emissions Controls Operating= 1,1 Barrels (bb0 per year Barrel (bbl) per year Barrel (bbl) per year Secondary Emissions -Combustion IAeiee(s). Heat content of waste el'31 w BC gas= �11�;r: a/acf Volume of waste gas emitted per year= 1742932.153 scf/year Actual heat content of waste gas routed to combustion device= Requested heat contentpfwaste gasroutedto combustion device= Potential to. Emit (PIE) heat content afweste gas routed to combustion device= Section 04 -Emissions Factors & Meshodoloeles Doesthe company usethe state default emissions factors to estimate emissions? Does the hydrocarbon liquid loading operation utilize submerged fill? Hydrocarbon Loadout 0 MMBTU per year 0 MMBTU nervear 0 MMBTU per year aflc stabilized hydrocarbon liquid sample must be providedto develop a site spedttc emissionsfactor, Pollutant Pollutant Uncontrolled Controlled )Ib/bbl) (Ib/bbl) (Volume Loaded) 0.011800 0.0000 0,000000 0.000000 0.000000 0,000180 0.000000 (Volume Loaded) 0.236000 0.000410 0,000000 0.000000 0.000000 0,003600 0.000000 Control Device Uncontrolled -, Uncontrolled (Ib/MMBtu) (Ib/bbl) (Volume Loaded) 0.0000 0,0000 0.5000 0,8000 0.0000 (waste heat combusted) 0 MENIEZI Emission Factor Source Emission Factor Source Section OS - Emissions Inventory Criteria Pollutants. Fntential to Emit Uncontrolled (tom/yearl Actual Emissions , Uncontrolled Controlled (mm/year) (torn/Year) Requested Permit Limits Uncontrolled Controlled (.m/year) (tom/year) PM10 PM2.5 toe NO5 VOC CO 0.00. 0.00 0.00 0.00 0.00 ' 0.00 0.00 0,00 0.00 0.00 0,00 0.00 000 0,00 ' 0.50 0,50 0.50 0.50 0.50 119.96 119.96 6,00 119,96 6.00 0.80 0.80 0,00 0.80 0.80 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (Ibs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) Ilbs/yearl Benzene Toluene Ethylbenzene xylene n -Hexane 224TMP 417 417 21 417 21 0 0 0 0 0 0 0 0 0 0 0 0 0 0 O 3660 3660 183 3660 183 0 0 0 0 0 31 of 33 _ K:\PA\2017\ 17WE0042.CPI.xlsm Hydrocarbon Loadout Emissions Inventory ,Sedlen 06 -Regulatory Summary Analysis Regulation 3: Parts A, R Source requires a perms. The loadout must operate with submerged fill and (cadent salvos must be routed to flare to satisfy RACT. RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applicability worksheetfordetailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements. Does the company request a control device efficiency greater Ulan 95%for a flare or combustion device? If yes, the permit will contain and initial compliance test conditionto demmsstratethe destruction efficiency of the combustion device basedoninlet and o Wet concentration sampling Saelon 09- Inventory SCC Coding and Emixions Factors AIRS Point0 001 Process #' SCC Code 01 406-001.32 Crude Oil: Submerged Loading Normal Service (5.J.6) Uncontrolled' Emissions Pollutant Fader Control% Unit PM10 0.00 0 b/1, 000 gallons transferred PM2.5 0.00 0 b/1,000 gallons transferred SOx 0.00 0 b/1,000 gellois transferred NOc 0.02 0 b/1,000 gallonstransferred VOC 5.6 95 b/1,000 gallons transferred CO 0.04 0 b/1,000 gallons transferred Bentene 0.01 95 b/1,000 gallonstransfened Toluene 0.00 95 b/1,000 gallonstmnsferred Ethylbentene 0.00 95 b/1,000 gallons transferred Xylene 0.00 95 b/1,000 gallons transferred n -Hexane 0.09 95 b/1,000 gallons transferred 224TMP 0.00 95. b/1,000 gallons transferred 32 of 33 K:\PA\2017\ 1NJE0042.CP1.xlsm Hydrocarbon Loadout Regulatory Analysis Worksheet Colorado Regulation 3 Park A end e.APEN and Permit Requirements (You hasa Indicated that smrne is is tha.'mu A[ielnmant Arica nAINMFNT 1, Are uncontrolled actual emission from any criteria pollutantsfrom this individual £ourceereatar-than 1TPt (Regulation 3. Part A, Seulon lLthl.ali 1. Is tMloadout located at an exploration and production site (e.g., well pad)(Regulation 3. Part 0, Sectionil.o.l.lit 3. Is thelaadeut opersfian loading iess 16.'10,000 galions lagal 55114 ofcrude dl per tlay on anannual average basis? 4. 6 the loadcut operation bating less than 6,750bbls per year &m&ensate via splash fill? 5. Is the loadaut operagen loading less than 16,308 bbls per year of condensate via submerged fill procedure? 6. Are total facility uncontrolled VOC emissions greater than 5 TPV, NOx greater than to TPrp CO emisdors greater tiara. TPT(Reguhdon 3, Part a, Section 6.51.3), Iynu bast Indicated ihs: sauces is=the 1.a-AllaMme 2 Area t1ATTAINMENT 1. Muncontrolled emission from any criteria pollutants from this Irdlvlduel source greakriWn]ITV (Regulation 3, Part A, Section he iwdoutioceted at an explaatlpn and productions. (e.g., well padl (Regulation 3, Part R, Section ll.O.l.li1 3. Is the loadout operation biding less than 10,000 gallon (138 8Mal denote dl perdayon an annual average basis? 4. Is the ioadout operation loading less than 6,750 b6s per year of condensate via splash BIN 5. Is the loadout operation loading less than 16,308 bbh12773,r of coMensak via submergd efill prxadun? 6. Are total facility uncontrolled VOO emissions from the greater than l TPy, NOx greater than 5 SPY ocCo emisslOra greater than 5 TPY (Reguatlon 3, Par[ B, Section 11.51.1)1 5a 0.ulra 7. RACr uncontrolled voCemissions born a loadout operation greater than 20 t lithe badoat mast npan:anitb till], Part 0, Section denote sari Disclaimer . This document assists gxntas with determining applcabldty &certain requirements d the Clean Air Act, Is urplemenUng regulations, ardAfr Quality Control Commission regulation. This document is not a rub a regulation, and Ihe anatysi3 it contains may not apply to a padieder situation based upon the Ixividual reels and circumstance. This document does not change cesubadtule fa-any/ew, regulation, a any other legally biling requitement and Is not HgaRy 001asaable In Ms event of any u378c1 between the language &thisdxumsntendthe language dge Glee n AirAcl„ its impletnenfIng regulations, and Air Quay Control Commission regulations, the language of the deletearegulatIon will control. The use ofno.maidatay language such as "ecardrax{" "may" "should; and "Deno' Is Wended to describe APCD Interpretations and recommendation. Mandatory to rind gy such as "mus1'one, 'Nuked'are Iierdd to dasedbe controlling requirements under the tame of the Clean Air Act and Air Quality Control C'rmmission regulagois, but this dxlment does not astabpst, laodybineengrequlemonk In and&itself. Go to next question. Go to the next question GO o next question Go to next question Go to next question The loadout requires a permit he loadout must operate with submerged (III and loadout emissions must be routed to control to satisfy RACT. If not controlled, a PACT analysis Is required and provide discussion In6ecdons. Permit number: Date issued: Issued to: COLORADO Air Pollution Control Division Department of Public Health & Environment. CONSTRUCTION PERMIT 17WE0043 Issuance: 1 Facility Name: Plant AIRS ID: Physical Location: County: Description: PDC Energy, Inc. Cockroft 19 Sec Pad 123 9F07 SENE, Section 19, T5N, R63W Weld County Well Production Facility Equipment or activity subject to this permit: Equipment ID AIRS Point Equipment Description Emissions Control TK-1 002 Eighteen 400 barrel fixed roof condensate storage tanks 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.cov/pacific/cdphe/other-air-permittinq-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.) 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 OLORADO liution Control Division f Publo Nettie', & Environment Page 1 of 7 • 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-1 002 -- -- 35.7 -- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant 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. 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-1 002 Enclosed flare VOC and HAPs 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 Air Pollution Control Division ; zy, rt mera.,DP Pubt }4, &th.6 C:virmment Page 2of7 TK-1 002 Condensate 1,016,600 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. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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) 11. 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) 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 & MAINTENANCE REQUIREMENTS CDFHE 41.1 'COLORADO I Air Pollution Control Division De,par.Jnent.nr Put b{eui't+ a E%;vironriert Page 3 of 7 15. Point 002: 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 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, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. 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 NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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 COLORADO Air Pollution Control Division. Page 4 of 7 "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self -certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self - Certify for Final Authorization section of this permit. 21. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or 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: Kirk Bear Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division. ' vYGa r[r:.ent d PubC,r. Health & &w&onre t 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 (Ib/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 2846 142 Toluene 108883 2948 147 Ethylbenzene 100414 203 10 Xylenes 1330207 1322 66 n -Hexane 110543 24703 1235 224 TMP 540841 203 10 Note: All non -criteria reportable pollutants in the table above w th uncontrolled emission rates above 250 pounds per year (Ib/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: Pollutant CAS # Uncontrolled Emission Factors lb/bbl Source NOx 0.138 lb/MM Btu TCEQ CO 0.276 lb/MM Btu TCEQ VOC 1.4027 Promax Benzene 71432 0.0028 Promax Toluene 108883 0.0029 Promax Ethylbenzene 100414 0.0002 Promax Xylene 1330207 0.0013 Promax n -Hexane 110543 0.0243 Promax 'COLORADO Air Pollution Control Division Page 6 of 7 Pollutant CAS # Uncontrolled Emission Factors lb/bbl Source 224 TMP 540841 0.0002 Promax Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised, APEN 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 requiremerrt 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 Operating Permit Synthetic Minor source of: VOC, HAPs PSD or NANSR Synthetic Minor source of: VOC, HAPs 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 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 Cortroi I5zvisan Page 7 of 7 Colorado Air Permitting Project Project Details - Review Engineer: Package #: Received Date: Review Start Date:, Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry. segment? Is this facility locai ted in a NAAQS non -attainment area? If yes, for what pollutant? I Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application CParticulate Matter (PM) Weld sSec Pad SENE quadrant of Section 19, Township 5N, Range 63WW, in Weld County, Colorado Quadrant I Section Township Range Izone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks E004° 002 47 TK-,1 4 � "� "_ - 3 .. 333.33,1 r�'.;;u0 . F'h=.r \\ \ rr4 Section 03 - Description of Project Section 04 - Public Comment Requirements Is Public CommentRequired? If yes, why? Section 05 - Ambient Air Impact Analysis Requirements 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 Colorado Air Permitting Project 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 here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) SO2 NOx CO VOC PM2.5 PM10 TSP ❑ ❑ ❑ CI O O ❑ ❑ ❑ O O ❑ O O SO2 NOx O HAPs ❑ CO VOC PM2.5 PM10 TSP HAPs ❑ ❑ ❑' O ❑ ❑ O O 0 Condensate Storage Tank(s) Emissions Inventory Section 01- Administrative information 'Facility AIRs ID: County Plan Poin 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 5,600: Barrels (bbl) per year 600: Barrels (bbl) per year Barrels (hbl) per year Secondary Emissions- Combustion Device(s) Heat content of waste gas=' +'_ Btu/scf Volume of waste gas emitted per BBL of liquids produced= s asm .;' scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Actual Condensate Throughput While Emissions Controls Operating = 0 MMBTU per year 0 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year Section 04- Emissions Factors & Methodologies Will this storage tank emitflash emissions? Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Condensate Throughput) (Condensate Throughput) VOC 5.070135 0.000140 0.000145 0.000010 0.000065 0.001215 0.000010 Benzene Toluene 0.0112 '0.002 Ethylbenzene Xylene n -Hexane 224 TMP j, ilieP 0002 jj�j}J�(Ii001,3; Pollutant Control Device - Emission Factor Source Uncontrolled Uncontrolled (lb/MMBtu) (Ili/bbl) (waste heat combusted) (Condensate Throughput) Emission Factor Source PM10 PM2.5 NOx CO 0.1350 02760. 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 713.0 713.0 35.6 713.0 35.6 PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.0 NOx 0.0 0.0 0.0 - 0.0 0.0 CO 0.0 0.0 0.0 1 0.0 0.0 Potential to Emit Actual Emissions .Requested Permit limits' Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year) Benzene 2846 2846 142 - 2846 142 Toluene 2948 2948 147 2948 147 Ethylbenzene 203 203 10 203 10 Xylene 1322 1322 66 1322 66 n -Hexane 24703 24703 1235 24703 1235 224 TMP 203 203 10 203 10 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A, 6 Source requires a permit Regulation 7, Section XILC, 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 X11.G Regulation 7, Section XVILB, C.1, C.3 Storage tank is subject to Regulation 7, Section XVI, B, C.1 & C.3 Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XV®.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, MACTSisbpart HH Storage Tank is not subject to MAC. HH (See regulatory applicability worksheet for detailed analysis) Barrels (bbl) per year 3 of 33 K:\PA\2017\17WE0043.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 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 emissionsfactors 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 maybe 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 # 002 Process# 5CC Code 01 Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM25 0.00 0 lb/1,000 gallons condensate throughput NOx 0.00 0 lb/1,000 gallons condensate throughput VOC 33.4 95 lb/1,000 gallons condensate throughput CO 0.00 0 lb/1,000 gallons condensate throughput Benzene 0.07 95lb/1,000 gallons condensate throughput Toluene 0.07 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.03 95 lb/1,000 gallons condensate throughput n -Hexane 0.58 95 lb/1,000 gallons condensate throughput 224 TMP 0.00 95 lb/1,000 gallons condensate throughput 4 of 33 K:\PA\2017\17WE0043.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Reg 1Ietion3Parts Aand B-0701 and Permit Requirements I You coon indlootod that source Is in 3hu Nan AtWlnment Area ATTAINMENT • 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section ll.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 end1.14 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 greaterthan OOTPY (Regulation 3, Part 0, Sectionll.D.3)? tyou have indicated that souree is in she Nnn•AthinmentArea NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than TPY (Regulation3, Part A, SectIonll.0.1.a)? 2. Is the construction date (service date) priorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 end1,14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, Nog greater than S TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.02)? 'Source requires a permit Colorado Regulation 7, Section XII.OF L Is this storage tank located in the 8 -hr ozone control area or any mane non -attainment area or attainment/maintenance area? 2. Is the 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 subjectta Regulation 7, Section XILC-F Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Section MD —Emissions Control Requirements section XII.E—Monitoring Section XII.F— Recordkeeping and Reporting Colorado Regulation 7.5ecelon XII.0 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 ate natural gas processing plant? 2, DIMS this s(prage tank eilhlklt "flash" (e.g, staring non-sta)llgg j)gwhiglgmissient apG htYf uncontrolled actual emissions greater than or equal to 2 tans per year VOC? I Stoma:Tank is not subject to Regulation 2, Section XII.G Section 011.0.2 - Emissions Control Requirements Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Sectlon XII.C.2—Emission Estimation Procedures Colorado Regulation 7, Section men 0. Is this tank located at a transmission/storage facility? 2. Is this condensate storage tanks located at an oil and gas exploration and production operation , well production facility°, natural gas compressor stations or natural gas processing plant? 3. Is this condensate storage tank a fed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOL? 'Storage took is subject to Regulation 2, Suction WO, 8, C'.1 & t.3 Section XVILB —General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1-Emissions Control and Monitoring Provisions Section )0/11.0.3 -Recordkeeping Requirements 5. Does the condensate storage tank contain only "stabilized" liquids? 'Storage tank is subjecttn Regulation 7, Section X111.02 Section XVlL[,2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part So. 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 (ms) (-472 Mils)? 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 petroleums or condensate stored, processed, or treated prior to custody transfer' as defined in 60.00tb? 3. Was this condensate storage tank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July23, 1984? 4. Does the tank meet the definitionef"stoage vessel"s in60.11eb? 5. Does the storage vessel store a'Volatile organic liquid )VOL)"s as defined in 60.211b? 6. Dom 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 ("20.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or I. The design capacity Is greater than or equal to 151 me (-950 BBL] and stares a liquid with a maximum true vapor pressure` less than 3.5 kPa (60.110blb))?; or c. The design capacity is greater than or equal to 75 Ms 1-472 BBL) but less than 151 ms ("950 BBL) and stores a liquid with a maximum true vapor pressure' less then 15.0 kPa(60.110b(b))? I Storage Tank is not subject tv NSPS Kb Subpart A, General Provisions §60.112b -Emissions Control Standards for VOC §60.113b -Testing and Procedures §6o.115b -Reporting and Recordkeeping Requirements §05.115k -Monitoring of Operations 40 CFO, Part 60. Subpart 0000, Standard of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this condensate storage vessel located ate (ability 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 90 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 stow a vessels In 40 CFR Part60 Mittart Kb or 40 CFR Part 63 sub art NN? 'Storage: Tank is notsubjecOM NSPS 0000 Subpart A, General Provisions per 560.5425 Table 3 §60.5395 -Emissions Control Standards for VOC 860.5413 -Testing and Procedures 860.5395(g) - Notification, Reporting and Recordkeeping Requirements 450.5416(c) -Cover and Closed Vent System Monitoring Requirements Yes Yes No Na Yes 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 faclllty 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 summary sheet. Source is subject 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 fl;4f _ 'Source is subject to all provisions of Regulation 7, Sections B&C Storage Tank Is not subject NSPS Kb - The storage vessel capacity is below the applicable threshold. Storage Tank is not subject NIPS Kb. Yes fmga Continue - You have indicated the source category on the Project Summary sheet. Go to the next question Storage Tank is not subject NSPS 0000. §60.5417- Control Device Monitoring Requirements [Note: lie storage vessel Is previously determined to be subject to NSps OOOO due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subject to NAPS 0000 per 60.53651e)(2) even if potential 600 emisslons'drop below 6 tons per year] 40 CFR, Part 63, Subpart MAR HR. 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' (63.76010)(2)); 06 b. A facility that processes, upgrades orstgres datural 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 user' (63,760(a)(3))7 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 63.7617 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 00007 'Storage Teak it not subjecttn MACT Hit SubpartA, General provisions per §.3.764 (a) Table 2 §63.766 -Emissions Control Standards 663.773 -Monitoring 463.774-Recordkeeping 463.775 -Reporting RACT Review YES 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 RACT requirements. Definitions for Drop Down Rent Yes No NA Yee Continue -You have Indicated the source category on the Project Summary sheet. Storage Tank is not subject MALT HH-There are no MAR HH requirements for tanks at area sources Crude Oil Storage Tank(s) Emissions Inventory Section 01- Administrative Information !Facility AIRS ID: County Plant Point 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 lank(s) Actual Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Throughput= Secondary Emissions - Combustion Device(s) Heat contentof waste gas= Volume of waste gas emitted per BBL of liquids II produced = 3;y3;;I 3'» scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device'= refs (bbl) per year rrels (bbl) per year . rrels (bbl) per year Btu/scf Potential to Emit (PTE) heat content of waste gas muted to combustion device = Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Section 05 - Emissions Inventory Pollutant VOC 224 TMP Pollutant Crude Oil Tank Uncontrolled Controlled (lb/bbl) (lb/bbl) (Crude Oil Throughput) (Crude Oil Throughput) 0.00 0.000 0.000 0.000 0 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) Emission Factor Source (waste heat. (Crude Oil combusted) Throughput) Actual Crude Oil Throughput While Emissions Controls Operating = 0 NpuIBTU per year 0 NTADTU per year 0 NEuIBTU per year Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit. Omits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0:0 0.0 0.0 0.0 0.0 . 0.0 0.0 0.0 0.0' • 0.0 0.0 r 0.0 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 n -Hexane 224 TMP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Section 06 - Regulatory Summary Analysis Regulation 3, Parts A,B Regulation 7, Section XVII.B, CI, C.3 Regulation 7, Section X‘/II.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8. Part E. NIACT Subpart 411 (See regulatory applicability worksheet for detailed analysis) Section 07 - Initial and Periodic Sampling and Testing Requirements Not enough information Not enough information Not enough information Not enough information Not enough information Not enough information 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 20 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specificemissions factor based on guidelines in PS Memo 14-03 7 of 33 K:\PA\2017\17W E0043.CPLxlsm Crude Oil Storage Tank(s) Emissions Inventory 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 of crude oil drawn at the faclity being permitted? lino, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03 Does the company request a control device efficiency greater than 95% for a flare or combustion device? 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 09- Inventory SCC Coding and Emissions Factors AIRS Point # 0 Process# SCC Code 01 Definitions for Drop Down Lists Storage Tank Emissions Factor Options Crude Oil State E.F. (includes flash) Site Specific E.F. (includes flash) Site Specific EPA TANKS E.F. Working and Breathing Only Other (Documented in Technical Analysis Notes) Qualifiers No Yes Not applicable - stabilized tank Control Devices Enclosed Flare Open Flare Vapor Recovery Unit (VRU) Control Device Combustion Emissions Factor Options NOx CO PM AP -42 Chapter 13.5 Industri AP -42 Chapter 13.5 AP-42Tahle 1.4-2 (PM10/PM.2.5) TNRCC Flare Emissions Guld TNRCC Flare Emissic Other- Explain AP -42 Table 1.4-1 (NOx) AP -42 Table 1.4-1(CO) Other- Explain Other- Explain SCC Codes - Storage Tank Emissions 4-04-003-12 Fixed Roof Tank, Crude Oil, working+breathing+flashing losses 4-04-003-02 Fixed Roof Tank: Working & Breathing Losses 4-04-003-22 External Floating Roof Tank, Crude Oil, working+hreathing+flashing 4-04-003-06 External Floating Roof Tank: Working and Breathing Losses 4-04-003.321 sternal Floating Roof Tank, Crude Oil, working+breathing+flashing 4.04-00307 Internal Floating Roof Tank: Working and Breathing Losses SCC Codes - Flaring Combustion Emissions 3-10001-60 Flares Uncontrolled Emissions Pollutant Factor Control% Units PM1O #DIV/01 0 lb/1,000 gallons crude oil throughput PM2.5 #DIV/01 0 lb/1,000 gallons crude oil throughput NO0 #DIV/01 0 lb/1,000 gallons crude oil throughput VOC 0.0 0 lb/1,000 gallons crude oil throughput CO #ON/Ol 0 lb/1,000 gallons crude oil. throughput Benzene 0.00 0 lb/1,000 gallons crude oil throughput Toluene 0.00 0 lb/1,000 gallons crude oil throughput Ethylbenaene 0.00 0 lb/1,000 gallons crude oil throughput Xylene 0.00 0 113/1,000 gallons crude oil throughput n -Hexane _ 0.00 0 lb/1,000 gallons crude oil throughput 224 TMP 0.00 0 lb/1,000 gallons crude oil throughput 8 of 33 K:\PA\2017\17W E0043.CP1.xlsm Crude Oil Storage Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B - APEN and Permit Requirements [You have indicated that source is in the Non -Attainment Area ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, isthe crude oil throughput less than 40,000 gallons per year? 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 II,0.3)7 IYou have indicated that source Is in the Non -Attainment Area NON -ATTAINMENT e 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 prior to 4/14/2014 and not modified after 4/14/14 (See PS Memo 14-03 for additional guidance on grandfather applicability)? 2a. If answer to #2 is yes, is the crude oil throughput less than 40,000 gallons per year? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? INot enough information Colorado Regulation 7, Section XVII 1. Is this tank located at a transmission/storage facility? 2. Is this crude oil storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this crude oil storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? No Yes INot enough Information 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 crude oil storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. INot enough information 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 (m3) ("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 m3 ("10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined In 60.1116? 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"3In 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate In excess of 204.9 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 m3 ["950 BBL] and stores a liquid with a maximum true vapor pressures less than 3,5 kPa (60.1105(b))?; or c. The design capacity Is greater than or equal to 75 Ms ["472 BBL] but less than 151 m3 [-950 BBL] and stores a. liquid with a maximum true vapor pressures less than 15.0 kpa(60.110b(b))? Continue - Continue - Not enough information Subpart A, General Provisions §60.1126 - Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60,116b - Monitoring of Operations - 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this crude oil 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 crude oil storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? Continue -` 3. Are potential VOC emissions' from the Individual storage vessel greater than or equal to 6 tons per year? 4. Does this crude oil storage vessel meet the definition of "storage vessel"1 per 60.5430? Not enough information Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Record keeping Requirements §60.5416(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 MACT HH, Oil and Gas Production Facilities 2. 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 liquids2 (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))? 1. Is the tank located at a facility that is major' for HAPs? 3. Does the tank meet the definition of "storage vessel"4 in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? INot enough information 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 RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing 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 ternlg of the Clean Air Act and'Alr Quality Contra! Commission regulations, but this document does not establish legally binding requirements in and of itself. Yes Continue - Produced Water Storage Tank(s) Emissions Inventory Section 01- Administrative Information 'Facility AIRs ID: County Plant Point 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 Produced Water Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Produced Water Throughput = arrels (bbl) per year Actual Produced Water Throughput While Emissions Controls Operating= Barrels (hhl) per year IIP Barrels (hbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas= �,,� � Btu/sd Volume of waste gas emitted per BBL of liquids produced = :rx'';9a"l7i'' ^;(scf/hbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = 0 MMBTU per year 0 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 0 MMBTU per year Section 04- Emissions Factors & Methodologies 4,4 Will this storage tank emit flash emissions? Pollutant ®'IMWMITE Produced Water Tank Uncontrolled Controlled (Ib/bbl) (lb/bbl) (Produced Water Throughput) Pollutant 91 lilliiME: (Produced Water Throughput) 0.00 0.000 0.000 0.000 0.000 0.000 0.000 Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) t3 its" 13;;13d3kl=lg'1;1133°a'I' (Produced Water Throughput) 0.0000 0.0000 0.0000 0.0000 Emission Factor Source Emission Factor Source 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 PM10 PM2.5 NOR CO 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 . 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (Ibs/year) Requested Permit Umits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylem n -Hexane 224TMP . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Section 06- Regulatory Summa Regulation 3, Parts A, A Not enough information Regulation 7, Section XVII.B, C.1, C.3 Not enough information Regulation 7, Section XVIl.C.2 Not enough information Regulation 6, Part A, NSPS Subpart 0000 Not enough information (See regulatory applicabilityworksheet for detailed analysis) 111111111111 11 of 33 K:\PA\2017\17WE0043.CP1xlsm Produced Water Storage Tank(s) Emissions Inventory Section 07 - Initial and Periodic Sampling and Testing Requirements 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 water sample drawn at the facility being permitted and analyzed using flash liberation analysis? This sample should be considered representative which generally means site -specific and collected within one year of the application received 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 emissidns factor. See PS Memo 14-03, questions 5.9 and 5.12 for additional guidance on testing. Does the company request a control device efficiency greater than 95% for a flare or combustion device?'�y, If yes, the permit will contain and initial compliance test conditionto 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 # 0 Process# SCC Code 01 4-04-003-15' Fixed Roof Tank, Produced Water, working+breathing+flashing losses Uncontrolled Emissions • Pollutant Factor' Control % Units PM1O #DIV/ol 0 lb/1,000 gallons liquid throughput PM2.5 #DIV/01 0 Ib/1,000•gallons liquid throughput Non #DIV/01 0 lb/1,000 gallons liquid throughput VOC 0.0 0 lb/1,000 gallons liquid throughput Co #Div/0! 0 lb/1,000 gallons liquid throughput Benzene 0.00 0 •Ib/1,000 gallons liquid throughput. Toluene 0.00 0 lb/1,000 gallons liquid throughput Ethylbenzene 0.00 0 lb/1,000 gallons liquid throughput Xylene 0.00 0 lb/1,000 gallons liquid throughput n -Hexane 0.00 0 lb/1,000 gallons liquid throughput 224 TMP 0.00 0 lb/1,000 gallons liquid throughput 12 of 33 K:\PA\2017\17WE0043.CP1.xlsm Produced Water Storage Tank Regulatory Analysis Worksheet Please note that NSPS Kb might be might be applicable for certain tanks at water management and injection facilities. If the tanks you are reviewing are at one of these facilities, please review NSPS Kb. Colorado Regulation 3 Parts A and B - APEN and Permit Requirements You have indicated that source is in the Non -Attainment Area ATTAINMENT - - 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 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 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)7 2. Is the operator claiming less than 1% crude oil and is the tank located at a non-commercial facility for'processing oil and gas wastewater? (Regulation 3, Part B, Section II.D.1.M) 3, Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)7 INot enough information . Colorado Regulation 7, Section XVII 1. Is this tank located, at a transmission/storage facility? 2. Is this produced water storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor stations or natural gas processing plant? 3. Is this produced water storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions°of this storage tank equal to or greater than 6 tons per yearr VOC? No Yes Not enough Information 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 produced water storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. INot anouglrinformation Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution 1. Is this produced water 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 produced water 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 produced water storage vessel meet the definition of "storage vessel"' per 60.5430? INot enough information Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413- Testing and Procedures §60.5395(g) - Notification, Reporting and Record keeping Requirements §60.5416(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)12) even if potential VOC emissions drop below 6 tons per year] CS - pJ Yes 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 RACT requirements. Disclaimer Continue - Continue - Continue - This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing 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 terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself. Glycol Dehydrator Emissions Inventory Section 01 -Administrative Information (Facility AIRs ID: County Plant Point Section 02- Equpment Description Details Dehydrator Information Dehydrator Type: Make: Model: Serial Number: Design Capacity: Recirculation Pump information Number of Pumps Pump Type Make: Model: Deslgn/Max Recirculation Rate: Dehydrator Equipment Flash Tank Reboller0utner Stopping Gas Dehydrator Equipment Description MMscf/day One(1) natural gas dehydration unit (Make: , Model: , Serial Number. ) with a design capacity of MMscf per day. This emissions unit Is equipped with (Make:, Model:) driven glycol pump with a design capatlty of gallons per minute. This dehydration unit is equipped with a still vent. Emission Control Device Description: Emissions from the still vent are routed to the . As a secondary control device, still vent emissions are routed to the Section 03- Processing Rate Information for Emissions Estimates Secondary Emissions -Combustion Device(s) for Air Pollution Control Sell Vend Control Condenser: Condenser emission reduction claimed: Primary control device: Primary control device operation: Secondary control device: Secondary control device operation: Still Vent Gas Heating Value: Still Vent . Waste Gas Vent Rate: Flash tank Control Primary control device: Primary controldevice operation: Secondary control device: Secondary control device operation: Flash Tank Gas Heating Value Flesh Tank Waste Gas Vent Rate: Control Efficiency % Control Efficiency % Control Efficiency % Wet Gas Processed: Still Vent Primary Control: 0.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Still Vent Primary Control: 0.0 MMscf/yr Still Vent Secondary Control: 0.0 MMscf/yr Wet Gas Processed: Flash Tank Primary Control: 0.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Waste Gas Combusted: Flash Tank Primary Control: 0.0 MMscf/yr Flash Tank Secondary Control: 0.0 MMscf/yr Glycol Dehydrator Emissions Inventory Section 04- Emissions Factors & Methodologies Input Parameters Inlet Gas Pressure Inlet Gas Temperature Requested Glycol Recirculate Rate STILL VENT Control Scenario Primary Secondary . Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) • Controlled (lb/hr) VOC �' 0 3 �31'ii;J1 a 0 Benzene :s sc�,*aiE;U';Ul3r 1 0 0 Toluene 5 0 Ethylbenzene S .:7_ U E hdlg 0 0 Xylenes li '% l /i)/USUJji?S(P,'�t'aa:,�` o 0 n -Hexane pmganowom - 0 0 224-TMP a U0U?.'UUi//y//t. ill 0 0 FLASH TANK Control Scenario Primary Secondary Pollutant Uncontrolled (lb/hr) Controlled (lb/hr) Controlled (lb/hr) VOC ) )� 0 0 Benzene '>U�s�.,.<. 0 0 Toluene 0 0 Ethylbenzene 0 0 Xylenes i(! 0 0 n -Hexane 5 0 224-TMP 0 0 Emission Factors Pollutant Benzene Toluene Ethylbenze 224 IMP Section 05- Emissions Inventory Did operator request b buffer? Requested Buffer)%): Glycol Dehydrator Uncontrolled (Ib/MMscf) )Ib/MMscf) (Wet Gas Throughput) (Wet Gas Throughput) Controlled DIV/01 DIV/e! DIV/01 #DIV/01 DIV/01 DIV/0! DIV/DI BON/0! DIV/01 4DIV 0! DIV/0!/1010/01 DIV/01 #DIV/0! 0.0000 Flash Tank Primary Control Device Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (lb/MMscf) (Waste Heat Combusted) (Waste Gas Combusted) Emission Factor Source Emission Rector Source Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tans/year) (tons/year) PM10 PM2.5 Non CO VOC 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (Ibs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) )lbs/year) Benzene Toluene Ethylbenzene Xylem it -Hexane 224IMP 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Glycol Dehydrator Emissions Inventory Section 06- Re ulatory Summery Analysis Regulation 3, Pares A, B Regulation 7, Seddon XVII.B,D Regulation 7, Se¢lon XVII.B.2.e Regulation 7, Serelon )(11.8 Regulation 8, Part E, MACTSubpart HH (Areal Regulation 8, Part E, MACTSubpart HH (Major) Regulation 8, Part E, MACTSubpart HHH (See regulatory applicability worksheet tor detailed analysts( Not enough Information Not enough information Not enough information Not enough Information Not enough information Not enough information You have indicated that thlsfacillty Is not subject to MAR HHH. Section 07- Initial and Periodic Sampling and Testing Requirements Was the extended wet gas sample used in the Glycalc model/Process model site -specific and collected within a year of application submittal? If no, the permit will contain an "Initial Compliance" testing requirement to demonstrate compliance with emission limi Does the company request a control device efficiency greater than 95% fora flare or combustion device? If yes, the permftwill contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 09- Inveetory SCC Coding and Emissions Factors AIRS Point 0 Process # SCC Code 01 o% Uncontrolled Pollutant Emissions Factor Control % Units PM10 #DIV/0. 0.0% b/MMsct PM2.5 #DIV/0 0.0% b/MMscf NOx 901V/0 0.0% b/MMscf VOC #DIV/0 #010/01 b/MMscf CO #010/0 0.0% b/MMscf Benzene #DIV/0 #019/01 b/MMscf Toluene #DIV/0 #810/01 b/MMscf Ethylbenzene #019/0 #DIV/01 b/MMscf Xylene #019/0 801V/01 b/MMsef n -Hexane #010/0 #015/01 b/MMscf 224TMP #01V/0 0019/01 6/MMscf Dehydrator Colorado Regul ATTAINMENT 1. Are uncont 2. Are total fa NON-ATTAINM 1. Are uncont 2. Are total fa Colorado Regul 1. Is this glyco 2. Is this glyco 3. Is the sum 4. Are actual t Section XII. MACT Ahab' 1. Is the dehy a. b. 2. Is the dehy 40 CFR, Part 63 Area SourcE 1. Is the dehy Exemption! 2a. 2b. 3. Is the unit I Major Sour 1. Does the fa Small or La 2a. 2b. Small Dehv 3. 4. 40 CFR, Part 63 1 Is the facilit Small or La 2a. 2b. Small Dehv 3. 4. Colorado Regul 1. Is the dehyi 2. Is this dehy 3. Is this deh 4. Was this glh 4a. 5. If construct Section XVI Section XVI Alternative 6. Regulatory Analysis Worksheet ation 3 Parts A and B - APEN and Permit Requirements You have indicated that source is in the Non -Attainment Area rolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Pa' cility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TF You have indicated that source is in the Non -Attainment Area ENT rolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, 5 cility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater thi Not enough information ation 7, Section XII.H d natural gas dehydrator located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/r )I natural gas dehydrator located at an oil and gas exploration and production operations, natural gas compressor of actual uncontrolled emissions of VOC from any single dehydrator or group of dehydrators at a single stationary uncontrolled emissions of VOC from the individual glycol natural gas dehydrator equal to or greater than 1 tpy (Re 'Not enough information — Emission Reductions from glycol natural gas dehydrators ISIS drator located at an oil and natural gas production facility that meets either of the following criteria: A facility that processes, upgrades or stores hydrocarbon liquidss (63.760(a)(2)); OR 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 user2 (63.760(a)(3))? drator located at a facility that is a major source for HAPs? Not enough information Subpart MACT HH, Oil and Gas Production Facilities e Requirements drator a triethylene glycol (TEG) dehydration unit (63.760(b)(2))? Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per d Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere ocated inside of a UA plus offset and UC boundary area? Not enough information Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring Standards §63.774 - Recordkeeping §63.775 - Reporting •ce Requirements icility have a facility -wide actual annual average natural gas throughput less than 0.65 MMscf/day AND a facility- rge Dehy Determination Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 3.001747 MMscf per d Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere Requirements Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.760(b)(1)(i)(B) For this small dehy, is a control device required to meet the BTEX emission limit given by the applicable equation Not enough information Subpart A, General provisions per §63.764 (a) Table 2 §63.765 - Emissions Control Standards §63.773 - Monitoring §63.774 - Recordkeeping §63.775 - Reporting , Subpart MACT HHH, Natural Gas Transmission and Storage Facilities :y wide actual annual average natural gas throughput less than 0.9994051 MMscf/day and glycol dehydrators the rge Dehy Determination Is the actual annual average flowrate of natural gas to the glycol dehydration unit less than 9.994051 MMscf per d Are actual annual average emissions of benzene from the glycol dehydration unit process vent to the atmosphere Requirements Did construction of the small glycol dehydration unit commence on or before August 23, 2011 (63.1270(b)(2) and For this small dehy, is a control device required to meet the BTEX emission limit (standard?) given by the applicabl You have indicated that this facility is not subject to MACT-HHH. Subpart A, General provisions per §63.1274 (a) Table 2 §63.1275 - Emissions Control Standards §63.1281 -Control Equipment Standards §63.1283 - Inspection and Monitoring §63.1284 - Recordkeeping §63.1285 - Reporting ation 7, Section XVII.D drator subject to an emissions control requirement under MACT HH or HHH (Regulation 7, Section XVII.B.5)? drator located at a transmission/storage facility? ydrator located at an oil and gas exploration and production operation , natural gas compressor station c ycol natural gas dehydrator constructed before May 1, 2015 (Reg 7 Section XVII.D.4.b)? equal to or greater than 6 tons per year VOC or 2 tpy VOC if the dehydrator is located within 1,320 feet of a building unit or designated outside activity area (Reg 7, Section XVII.D.4.b)? :ed on or after May 1, 2015, are uncontrolled actual emissions from a single glycol natural gas dehydrator equal to INot enough information II.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions II.D.3 - Emissions Reduction Provisions Emissions Control (Optional Section) Is this glycol natural gas dehydrator controlled by a back-up or alternate combustion device (i.e., not the primary Not enough information Section XVII.B.2.e - Alternative emissions control equipment Disclaimer Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing 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 Yes Yes Yes Continue - You have indicated the attainment status on the Project Summary Sheet. Continue - You have indicated the facility type on the Project Summary Sheet. Continue - Source is subject to MACT HH requirements. You have indicated the source category on t Continue - You have previously indicated this in the beginning of the MACT section Continue - You have previously indicated this in the Reg 7, Section XII determination he Project Summary Sheet. Hydrocarbon Loadout Emissions Inventory Section 01 -Administrative Information Facility AIRS ID: County Section 02 -Equipment Description Details Detailed EmissIons Unit Description: Emission Control Device Description Is thiloadout controlled? Collection Efficiency: Control Efficiency: 95.00 Requested Overall VOC & HAP Control Efficiency %: Pia Section 03 .,Processing Rate Information for Emissions Estimates Primary Emissions- Hydrocarbon Loadout Actual Volume Loaded= Requested Permit Limit Throughput= Potential to Emit IPIE) Volume Loaded =# glipminral Point IS' Barrels(bbi) per year Actual Volume Loaded While Emissions Controls Operating= C13 i Barrels(bbl) per year l0 Barrels (bbl) per year 70 Barrels (bbl) per year Secondary Emissions -Combustion Device(s) Heat content of waste gas = 3�' � c;O�Btu/s6 Volume of waste gas emittedperyear= 1482969.301 scf/year Actual heat content of wastegas routed to combustion device= Requested heat content of waste gasrtutedto combustion device= Potential to Emit (PIE) hat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies Does the company use the state default emissions factors to estimate emissions? Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facd being permitted? Loading Lass Equation L=1146" 5'P'M/T 0 MMBTU per year 0 MMBTU per year 0 MMBTU per year A site spedficstabillzed hydrocarbon liquid sample must Mt provided to develop a site specific emissions factor. Factor Meaning Value Units Source 5 Saturation Factor 0.6 P True Vapor Pressure . ,: a SA ti: psis �., I)1UIt°t/I v :: ,'.: ptPlna# ,,...` 'I ., • �, •^I '$ M Motmular Weight of Vapors '. 52,77,,,;. lb/Ib-mol T Liquid Temperature t3333t515194B44 Rankine ; pi " 3.33 a3j33 d'>f L Loading Losses 4.78lb/1000 gallons ' = 0.20 lb/bbl Component Mass Friction Emission Factor Units Source Benaene OrtMEBBMOMBIBMOM,0.0004 lb/bb Toluene "'1i.:0fi.'fiiAi3I.3.4'eiatl 0.0005 lb/bbl Ethylbemene 0.0000251 lb/bbl a - - ptanasc 71 il 3 3113 ii 3 :1: lEylene " 3 3 333?)3 3,y . ,3 0.0002 lb/bbl - - 3 - paomaa T 33 31riti 3X311 it 3) n -Henn >L ¢ }' l 0.0039 lb/bbl ; :- -- )sronvau „ ,.,, 5 3 �•i3': 224 TMP _ _' 0,0000330 lb/bbl Pollutant Pollutant Section 05 -Embalms Invenmrl- Hydrocarbon loadout Uncontrolled Controlled (lb/bbl) (lb/bbl) (volume Loaded) 0.010040 0.000020 0.000025 0.000001 0.000010 0.000095 0.000002 (Volume Loaded). 0.200800 0.000400 0..0000500 0.000025 0.000200 0.003900 0.000034 Control Device Unnsntra6ed (lb/MMBtu) Uncontrolled (Ib/bbi) (Volume Loaded) 0.0000 0.0000 0.50000 0.8000 0.0000 (was. heat combusted) Emission Parma -Source Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled Pam/year) Actual Emissions Uncontrolled Controlled Imm/yearl Irom/ycer) Requested Permic Limits Uncoimolled Controlled Bons/Year, Rom/Wed PM10 PM15 508 601 VOC CO 0.00 0.00 0.00 0.00 0.00 6.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.50 0.50 0.50 0.50 0.50 10107 102.07 5.10 102.07 5.10. 0.80 0.80 0.80 0.80 0.80 Hazardous Air Pollutants Poten0alto Emit Uncontrolled (Dios/year) Actual. missions Uncontrolled Controlled Ilbs/yeer) (Ibs/year) -Requested PermitLlrnits Uncontrolled Controlled • (Ibs/yearl (lbs/yeasrl Benzene Toluene Ethyibenzene Oylene n -Henn 224 TMP 407 407 20 407 20 508 508 25 508 25 26 26 1 26 1 203 203 10 203 10 3965 3965 198 3965 198 34 34 2 34 2 31 of 33 K:\PA\2017\ 17WE0043.CPtolsm Hydrocarbon Loadout Emissions Inventory Section 06-Regoiat Summary Analysis. Regulation 3, Parts A, B RACT- Regulation 3, Part B, Section III.D.2.a (See regulatory applimbiliry worksheet for detailed analysts) Se0lan 02-leitlal and Periodicnampling and Testing Requirements Source requires a permit The loadout must operate with submerged fill and loadout emissions mast be routed to flare to satiety RACT. Does the companyrequest control device efficiency greaterthan 95%fora flare or combustion device? If ye, the perm& will contain and inittalcompllancetetcondrior to demonstrate the detraction efficiency niche combustion device based on inlet and outlet concentration sampling •SeGIrc 08-Tedmial Analysis Note AIRS Point# 001 Section 09 -Inventory SCC Coding and Emissions Factors Process # SCC Code 01 4.06-00142 Crude Oil: Submerged Loading Normal Service (Sa0.6) Uncontrolled Emissions PollutaFactor nt Control% Units PM10 0.00 b/1,000 gallons transferred PM25 0.00 b/1,000 gallons transferred SOx 0.00 b/1,000 gallons transferred NOx 0.02 . b/1,000 gallons transferred VOC 4.8 5 6/1,000 gallons transferred CO 0.04 b/1,000 gallons transferred Benzene 0.01 9 b/1,000 gallons transferred Toluene 0.01 9 b/3,000 gallons transferred Ethylbenzene 0.00 9 b/1,000 gallons transferred 031000. 0.00 9 , b/1,000 gallons transferred n -Hexane 0.09 9 b/1,000gallonstransferred 224TMP 0.00 9 b/1,000 gallons transferred 32 of 33 Hydrocarbon Loedoet Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and t. APEN and Permit tequlrements Frov have indkatod that spume fs ion thu:eon Atlelnnsent Aran ATTAINMENT - ---- 1, Are uncontrolledactual emIssiorn from any critmie pollutant from tun Individual source greater than 22.2 (Regulation 3, PeyA,seeden I1.u.1.aR 2. Is the loadot located atom exploration and production site{e.g., well pad)(Regulation3, Part%Section 11.0.1.1)? 3. Is tieloadout operation loadingler till, so,oco gallons (238001x)orcrude of perch. an annual average basis? 4. le the loadout operation loading less Nan 6,250 bads per year ofmnlereate sir sdashrli? 5. Is the loadout operation loading less than 16,900 bbls per year of condensate vb submerged Illprosedure? 6. Are total Nullity uncontrolled PDC emlsslons greater than TPY, NOP greater then 10 T% orCO emisslomgreaser than to PPY(Regulation 3, Part B, 5ectlonll.D.311 yo:: have lndtea132 the sofas Is tniha 044,21talnme01 Area NON-AITAINMENT ore from any W tech polumnt from Ws ir.Mdual source greater Nan1TPf (Regulation 3, PartA, Section Rata), 2. Is the loadou t Incased at an exploration and produ atom site (e.g., well pad) (Regulation 3, Part 0, 5ectIon II.0.1.1 3.t the l0doutopera00, loading less Man 10,100 gallons (238 081s)ol codeoff nerds,'co an annul averagebasis? 4. Is the loedout operation loading less than 6,250 bbls per year of condensate Nesplash fill? 5. Is the tondo. open0on loading less than 16,808 bids per year of coulenate ale submerged IN pr2 6. Are total (malty uncontrolled POC<missionsfrom the one., than 2TRY, NOs greater than 5 TP2or<Oemisslots lau Cygreater Nan 5 TPy ieegulaton3 Part g,Sectlonll.0W ISonsou require, a parrots 7. BAR -Are uncontrolledvoC emissions Rom the loadaut operation ureate,Mon20Ny(Iegula6. 3, Porte, 5edbnIlE42e)2 1Tha?oacactmust opeoe'.00 tb ootbmomed tls.,d leadau00mialunamust bemeuted?u gam tosatisfe R Go to nod qumtlon. Go to Me xtqua8an Go to next soon Go to eat question Bier'Go to nel4 question The Mario. requires a permit ia'z Aighalg 61u Uledaimer This rbcurneht assists operators with dataminilg applicability a( tenet) requirements tithe Clean Ai Acl, Is Implamenting mguiallpns, and Air quality ConhW Commission regulations. This dcumenl Is not a ruh orregolatior, and the analysis it contain may not apply to a particular situation based Soon the individual hots ardc.cumstances. This dxumantdces dal charge or substitute O,reny law, regulation, or any otherlegaly blrs9fg requisntel exits not legalyapfocsebb. In Ilhaventdea) coaitclbah000ofhelergwge Wildsdxumeatsna krguege an. Chen Air Ash, Os Impkrnantirg ovulations. erdAir Quality Conbd Copadsska regulations, tselanguage, eit oetatute orregulation will contra The usedson-shrydatey language sashes 5ae,s,e ,'-may.'"shadd'endbandit mtaradm dasciibeAPCO mlarprntatlms ad recorurendelk»s. Mandatory lemtrlobgy such as hnusrae"egoofi r are blends db describe controlling requlrernants on:fertile terra of MGM., sn AlrAot and Air Quality Contra bwmdsslon regulations, but this document class not estebgsh Segaify thing requirements In endo ise . W79.49'£tix The Ioodout must operate M. submerged 011 and Imdout emissions must be routed to sonoul lsrsor y RAC). If not conboned, a PACT analysts is required and provide mscnsslon In Sealant, 7 RECEIVED l&g APCu Hydrocarbon Liquid Loading APEN Form APCD-208 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 Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN {Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of alt available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.Rov/cdphe/apcd. , This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 11 W0042 AIRS ID Number: 23 /aF01 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Cockroft 19 Sec Pad Site Location: SENE Sec 19 T5N R63W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 E -Mail Address2: elizabeth.duncan@pdce.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Elizabeth Duncan Phone Number: (303) 860-5800 '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. 357139 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 12/2016 1 I &® COLORADO Deportment of wain . xrlm a &rvunnmsm Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action O NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit -OR - ❑ Request coverage under General Permit GP073 MODIFICATION to existing permit (check each box below that applies) Change fuel or equipment ❑ Change permit limit ❑ Change company name Transfer of ownership4 O Other (describe below) - OR • APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Initial permit request for new facility; ECD to be installed 2/2017 with 95% control efficiency 3 In addition to the APEN filing fee ($152.90), a General Permit fee of $250.00 will be assessed. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Liquid Loadout Facility equipment Identification: LOAD -1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 10 /8 / 2016 Will this equipment be operated in any NAAQS nonattainment area? • Yes O No Is this equipment located at a stationary source that is considered a Major Source of (HAP) ❑ Yes 0 No emissions? Does this source load gasoline into transport vehicles? ❑ Yes ❑✓ No Is this source located at an oil and gas exploration and production site? 0 Yes ❑ No If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? 0 Yes EYes No Does this source submerge fill less than 16308 BBL of condensate per year? ❑ Yes E No COLORADO Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 2 I A- H°`°»-� Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑✓ Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: 1,016,600 Bbl/yr Actual. Volume Loaded: 1,016,600 Bbl/yr 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") Tank Trucks If site specific emission factor is used to calculate emissions, complete the following: - - Saturation Factor: 0.6 Average temperature of bulk liquid loading: 56.461 ° F True Vapor Pressure: 6.3329 Psia @ 60 °F Molecular weight of displaced vapors: 52.166 Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Actual Volume Bbl/yr Loaded5: Loaded: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth Bbl/yr Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 COLORADO 3 I A-��° n.�vn 6 &nnnme.m Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates Latitude/Longitude or UTM) -; 40.38806 / -104.47418 ®„,,, Sta `?' a o tseffirg x eigh � 1+ ';15ea" _ #,�w �.'.`1i yy� Ft ' Y �. _ c' .. �p._ _„ ACF,ft7s f� .. ... Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC, BTEX, HAPs Enclosed Combustor Requested Control Efficiency: Manufacturer Guaranteed Control Efficiency: Minimum Temperature: MMBtu/hr Make/Model: TBD (To be installed 2/2017) 95 % 98 % Waste Gas Heat Content: Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: Btu/scf MMBtu/hr ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: 0/0 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 COLORADO 4 I L., rerun s &wi�o�meni Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): PM Overall Requested Control Efficiency (%reduction in emissions SOX NO,, CO VOC Enclosed Combustor 95% HAPs Other: #12CUsing State Emission Factors (Required for GP07) VOC )Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene 0.00041 Lbs/BBL 0.00018 Lbs/BBL n -Hexane 0.0036 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2016 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Uncontrolled Pollutant Emission Factor PM Emission Factor "Units Emission, Factor Source (AP -42, Mfg. etc) Controlled6 Uncontrolled (Tons/year) (Tons/year);.- Controlled (Tons/year) Uncontrolled (Tons/year) SOX NO,, 0.138 Ib/Mit9Btu TCEQ N/A 0.41 (DM) N/A 0.41 (DM) CO 0.276 lb/MMBtu TCEQ N/A 0.83 (DM) N/A 0.83 (DM) VOC a t2 -9.2008 lb/bbl a-02-09 -49-62 i2•O4-92..439. le -49-62 Benzenep.poo9 1 .-Bee- lb/bbl -ProMax 45 4,41a/yr -22O 31Itr/yrei1 458 lb/yr -2.20.63-I1a/yi -men 161.,G4-Ib/yr 22 b/yi ' 224.O6-Ib/yr .57 _ Iblyr- BM --- 2.43 lb M3- b/bbl PluMax 204 811b1 y yr(D 5 tblvr([ )--- n-Hexane 0,0030, .B Q lb/bbl -PfoA ax- 3941711-1b/yr Tnl�entane- ---PeMax 34 O9154G-14r -94919111 lb/yr .1.1,© b yyr�l]t�nl_ 34 4 , ,r iI 767.1"3-144 16,Wa-Ibhir-�BM Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. 163 Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 COLORADO Health 6 Envircnmanf Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct.• � 1",,,. t /412017 Signat &-'j f Legally. Authorized Person (not a vendor or consultant) Date Elizabeth Duncan EHS Professional Name (print) Title Check the appropriate box to request a copy of the: z 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 registration fee of $250 as 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 For more information or assistance call: 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-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 6 A® COLORADO D.MP Fu1M 6 & htanmrtna AIR POLLUTANT EMISSION NOTICE (APEN) & Application for Construction Permit — Condensate Storage Tank(s)1 t Niiimber: 1 i WE 004-3 y- Equipment ID: TK-1 ',Section 01- Administrative Information Company Name: PDC Energy, Inc. [Leave blank unless APCD has already assigned a permit # & AIRS ID] Emission Source AIRS ID: 2.3 /61 PO -1 / 002 - [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] Section 02 — Requested Action (Check applicable request boxes) • Request for NEW INDIVIDUAL permit ❑ Request for coverage under GENERAL PERMIT ❑ GP08 oirce Name: Cockroft 19 Sec Pad ` Source Location: SENE Sec 19 T5N R63W Mailing Address: 1775 Sherman Street, Suite 3000 Person To Contact: E-mail Address: Denver, CO NAICS, or 1311 SIC Code: County: Weld Elevation: 4555 Feet ZIP Code: 80203 Elizabeth Duncan Phone Number: (303) 860-5800 Elizabeth.Duncan@pdce.com Fax Number: (303) 860-5838 Section 03 — General Information For existing sources, operation began on: 10 This Storage Tank is r Exploration & Production Located at: (E&P) Site 8 / 2016 ❑ Midstream or Downstream (Non-E&P) Site Will this equipment be operated in any NAAQS nonattainment area? ® Yes ❑ No Is actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? ® Yes ❑ No D. Are these condensate tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 805 series rules? If so, submit Form APCD-105. ► 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 Condensate Throughput: Requested Permit Limit: Actual: Average API Gravity of Sales Oil: Tank Design: Fixed Roof: N/A bbl/year 1,016,600 bbl/year Actual While Controls Operational: 1,016,600 bbl/year 49.4 degrees Internal Floating Roof: RVP of Sales Oil 10 ❑ 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 18 7200 6/2016 10/2016 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-43012 Cockroft 19U-334 ►. 05-123-43014 Cockroft 19U-404 ►1 05-123-43007 Cockroft 19V-204 ►.I 05-123-43009 Cockroft 19V-214 L 05-123-43011 Cockroft 19V-234 ►1/ ❑ GP01 ❑ Request MODIFICATION to existing INDIVIDUAL permit (check boxes below) El Change process or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership El Other ❑ APEN Submittal for Permit Exempt/Grandfathered source ❑ APEN Submittal for update only (Please note blank APEN's will not be accepted) Addl. Info. Initial permit request for new facility & Notes: For new or reconstructed sources, the projected startup date is: hours/ Normal Hours of Source Operation: 24 day 7 / / days/ week Are Flash Emissions anticipated at these tanks ® Yes If "yes", identify the stock tank gas -to -oil ratio: 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 -$452.90 for up to five (5) APENs for E&P sources and45_0.for each general permit registration to: ' RF Colorado Department of Public He t Environment APCD-SS-B1 4300 Cherry Creek Drive South �J' 4,%" Denver, CO 80246-1530 s;t, For guidance on how to complete this N -forth Air Pollution Control Division: "--(303) 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 357138 Page 1 of 2 TK-1 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 Eatian., : (feet) StackDischarge ' Height Above Ground Level (feet) Temp.. (°F) Flow Rate (ACFM) Velocity (ft/sec) Moisture (%) ____J Direction of stack outlet (check one): ❑ Vertical ❑ Vertical with obstructing raincap Exhaust Opening Shape & Size (check one): ❑ Circular: Inner Diameter (inches) = .Qartinn O7 — rnntrnl ilpvi, p Infnrmatinn ■ Vapor Recovery Unit (VRU) used for control of the Storage Tank(s) Size: Make/Model: // Combustion Device used for control of the Storage Type: Enclosed Combustor Tank(s) Make/Model 95 % Rating: MMBtu/hr 7 x Cimarron 48", 1 x Cimarron 60" Requested VOC & HAP Control Efficiency: % % VOC & HAP Control Efficiency: Requested: Minimum temp. to achieve requested control: Constant pilot light? I Yes ■ No 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) Pilot burner rating: MMBtu/hr Description: ■ Describe Any Other: 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)? 19 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 Easting or Longitude.' (meters. or degrees) ".17TH Northing or . Latitude (meteror degrees) Method of Collection for Location Data (e.g.map, GPS, GoogleEarth) WGS 84 -104.47418 40.38806 COGCC Website ❑ Horizontal LI Down ❑ Other: Length (inches) = ❑ Other (Describe): Width (inches) = Please describe the separation process between the well and the storage tanks: Three -Phase Separator psig 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): I 2016 Pollutant Emission Factor Actual Calendar Year Emission ' Requested Permitted Emissions Emission Factor Data Source Uncontrolled Basis Units Uncontrolled (Tons/Year) Controlled (Tons/Year) Uncontrolled (Tons/Year) Controlled (Tons/Year) NOx 0.138 lb/MMBtu N/A 2.89 N/A 2.89 ' TCEQ VOC 1.4027 lb/bbl 712.99 — 35.65 712.99 35.65 ProMax CO 0.276 lb/MMBtu N/A 5.77 N/A 5.77 — TCEQ Benzene 0.0028 . lb/bbl 2843.81 lb/yr 142.19 lb/yr ' 2843.81 lb/yr 142.19 lb/yr ProMax Toluene 0.0029 lb/bbl 2918.60 lb/yr 145.93 lb/yr 2918.60 lb/yr 145.93 lb/yr ProMax Ethylbenzene 0.0002 lb/bbl 165.05 lb/yr (DM) 8.25 lb/yr (DM) 165.05 lb/yr (DM) 8.25 lb/yr (DM) ProMax Xylenes 0.0013 lb/bbl 1331.82 lb/yr 66.59 lb/yr 1331.82 lb/yr ' 66.59 lb/yr ProMax n -Hexane 0.0243 lb/bbl 24714.05 lb/yr 1235.70 lb/yr 24714.05 lb/yr 1235.70 lb/yr ProMax 2,2,4-Trimethylpentane 0.0002 lb/bbl 239.62 lb/yr (DM) 11.98 lb/yr (DM) 239.62 lb/yr (DM) 11.98 lb/yr (DM) ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report 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. t(tipNOl7 Signa e of Person Legally Authorized to Supply Data Date Name of Legally Authorized Person (Please print) ` Title t 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. Elizabeth Duncan EHS Professional Additional Information Required: LI 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) Attach EPA TANKS emission analysis if emission estimates do not contain working/breathing losses El Check box to request copy of draft permit prior to issuance. Check box to request copy of draft permit prior to public notice. FORM APCD-205 Page 2 of 2 TK-1 APEN E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: PDC Energy, Inc. Source Name: Cockroft 19 Sec Pad Emissions Source AIRS ID2: N/A / 12.3 / 'i F )1- 002 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 -123 - 43010 Cockroft 19V-304 r 05 - 123 - 43006 Cockroft 19V-314 F� 05 - 123 - 43013 Cockroft 19W-214 [ 05 -123 - 43008 Cockroft 19W-314ST A - - ❑ - - ❑ - - ❑ - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - ❑ Footnotes: 1 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 Appendix Hello