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HomeMy WebLinkAbout20180255.tiffCOLORADO - RECEIVE® Department of Public Health ft Environment 1 1 2018 Dedicated to protecting and improving the health and environment of the people of Colorado WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board 1150 O St PO Box 758 Greeley, CO 80632 January 9, 2018 Dear Sir or Madam: On January 11, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Brown 23 Sec HZ; 23-43. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-153O P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer �u �1�� R2v►i?,c,� cc: FLC i 0NA ITP) , N t -(3`r) Ol-2.d4 fig PW CER f CH jSMLCK) of -12-c$ 2018-0255 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Brown 23 Sec HZ; 23-43 - Weld County Notice Period Begins: January 11, 2018 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: Brown 23 Sec HZ; 23-43 Well Production Facility SWSE of Section 23, Township 5N, Range 65W Weld County The proposed project or activity is as follows: The operator is requesting permit coverage for sixteen (16) 538 barrel and one (1) 300 barrel fixed roof storage vessels located at a synthetic minor well production facility. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) • the 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 17WE0772 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: Harrison Slaughter Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01:- Facilitylnforniation Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS If yes, for what pollutant? Browec HZ; 2l SWSE quadrant of Section 23, Township 5N, Range 65W, in Weld County, Colorado. Exploration & Production Well Pad Oil & Natural Gas Production. & Prose. non -attainment area? Yes Earbon Monoxide (CO) ❑'articulate Matter (PM) Quadrant -- .6ection 02 - Emissions Units In PermitAppiication axone (NOx & VOC) Section Township Range AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 007: Condensa4eTani< TK-1 Yes 17WE0772 1 Yes PermitInitial Issuance. Section 03 - Description of Project PDC Energy, Inc. submitted an applieW faculty located in the ozone nonatt (Colorado Regulation 3 Part A Section;ll! Regulation 3 Part B Section II.0 2.a.).' Public comment will be required forth of this project are greaterthan 25 tpy. Section 04 Public. Comment Requirements Is Public. Comment. Required? Yes If yes, why? Requesting Synthetic fvi Requesting traditional permit coverage for condensate storage vessels at an existing exploration and production t area. The condensate tank included in this application is APEN required because uncontrolled VOC emissions are > 1 tpy This source also requires a permit because uncontrolled actual VOC emissions from theifaciirtypre greater than 2 tpy (Colorad 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. request synthetic minor Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a -true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR), Is this stationary source a major source? If yes, explain what programs and which -pollutants here: - Prevention of Significant Deterioration (PSD) Title V Operating Permits. (OP) - Non -Attainment New Source Review (NANSR) SO2 NOx ❑ El Ef ❑ 0 CO VOC ❑: O ❑ ❑ 0 o avoid other requirerne nts and the change in VOC emissionSipsa result- - PM2.5 PM10 TSP ❑ ❑: ❑. -❑ SO2 NOx CO VOC - Pfvl2.5 PM10, TSP HAPs ❑ ❑ ❑ ❑, ❑ a. ❑ ❑ ❑ ❑ ❑- ❑` 0. ❑ ❑ ❑` Condensate Storage Tank(s) Emissions inventory. 'Facility AIRS ID: ....ii3 ',aA Nara,„x,,,_4427 404" fj) County Plant Point Section 02; Equipment Description Details Detailed Emissions Unit Decrpaon. Emission Control Device Description: Requested Overall VOC &HAP Control Efficiency 96: Sectlbn 03- Processing Rate Information for Emissions Estimates. • Primary Emissions -Storage Tank(y). Actual Condensate Through put= Requested Permit LlmitThroughput=. Potential to Emit (PIE) Condensate Throughp Barrels (bbl) per year Barrels (bbl) per year Barrels (bbl) per year • Secondary Emissions- Combustion Devke(s) Heattontent of waste gas= Btu/sri Volumeof waste gas emitted per BBL of liquids produced= :-m;:a8313313 l scf/bbl Actual heatcontent of waste gasrouted to combustion device - Requested heat content ofwastegas routed to combustion device= Potential to Emit (PTE) heat content of waste gasrouted to combustion device = Section 04- Emissions Factors & Methodologies Mirth's storage tankemdflash emissions? Pollutant Uncontrolled (lb/hrl Source VOC Benzene qi Toluene Ethylbenzene Xylenes n -Hexane 2,2,4 -IMP (lb/bbl) (Ib/bb1) tO Actual Condensate Throughput While Emissions Controls Operating = ,7.x.'„1,8,21 MMBTU per year 77,192 MMBTU per year. 92,630 MMBTU peryea4 Pollutant. (Condensate Throughput) (Condensate Throughput( Emission Factor Source iliZSIMINIIIIIIIIMEMMEMENI, • MIMMTMCMIE=INIMEMME0. at r rimafuuru:.=si_ 3.007604 lanZEM®" 6.494E-02®' Pollutant Section OS -Emissions Inventory 2080E-04 Control Devi (waste heat combusted) (Conden Throughput) 0.6000 0.0000 Emission Factor Source Criteria Pollutants Potential to Emit Uncontrolled ' Icons/year) Actual Emissions Uncontrolled Controlled . (tons/year) (tons/year)+ Requested Permit Limi6 Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 • PM2.5 ' NOD ' CO 1577.16 1314.30 65:72 . 1314.30 69.72 0:00 0.00 0.00 0.00 0.00 - 0.00. 0.00 0.00 0.00 0.00 6.39 5.33 5.33 5.33 5.33 12.76 10.63 10.63 10.63 10.63 Hazardous Air Pollutants Potential to Emit Uncontrolled (Ibs/yexr) Actual Emissions Uncontrolled Controlled nbr/vear) (An/year)' Requested Permit Limits Uncontrolled Controlled (l s/year) (lbs/year) - Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 7710.05 6425.32 321.27 6423.32 321.27 • 10893.88 9028.24 451.41 9026.24- 45141 ' 326.69 272.24 13.61. 272.24 13.01 4519.50 ' 3766.25 181{:31 3766.25 188.31 70540:91 58784.11 2939.21 58784.11 2939.21 490.42 358.68 17.93 358.68 17.93 Section 06 - Regulatory $6mmanrAnalysis Regulation 3, Parts A, B Regulation 7, SettfonXll.C, D, E, F Regulation 7, Section 101.0, C Regulation 7, Section 0011.0, C.1, C.3 Regulation 7, Section XVII.C,2. Regulation 6, Part A: NSPS 5ubpart Kb . Regulation 6, Part A. HOPS Subpart OOOO FLOPS 0000a Regulation 0, Part E, MACE Subpart HH (See rogulatnry applicability worksheet for detailed analysis) Source requbez apermb Storage tank is noblest to.Regulatlon 7,Section KILC-F Storage Tank is notsublectto Regulation 7, Section XII.0 Storage tank is subject to Regulation 7, Section kill, B, CI &C.3 Storage tanks sublet to Regulation 7, Section XVII.C.2 Storage Tank is not subject to NSPS Kb Storage Tank is not subjectto NSF, 0000 Storage Tank is notsubiat to SOPS 00005 Storage Tank la not subjectto•MACT HH Barrels (bbl) per year 2 of 5 K:\PA\2017\17 W ED772. CP1ads m Condensate Storage Tank(s) Emissions Inventory Secden07-Initial and Periodic Sampling and Tesdne Requirements Does the company usethestate default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimatedto be greater than or equal to 80 tons VOC peryear? '2"" _ /A- = =mil. _ .."'{N Operator developed site specific emissions factors mestimate emissions I£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 sampleshould be considered representattvewhlch generally means site-specifIC and collected within one year of the application received date. However, iifthe facility has not been modified (e.g., no w 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 05-0 Does the company request a control device efficiency greater than 95%for a fire or combustion device? If yes, the permit will contain and Initlal compliance test condition to demonstrate the destruction efficiency of the combustioiWeiice based on inlet and outlet concentration sampling Section ee-Technical Analysis Notes iE.Tygiralkibasecandaryedmbastionemtsstaiearedattutateduringttuewritsgoesflowrutsandheatauntentpredlatod.Bgtha tnodslceodtwaot FroMaostmaladpnthatotalwastegasffawratewasoprediutedtubmRA83S40 ..MMsafldaydlaslram WJegazl+Addkkcatlyga gaa3tmenyl.4174l-9tufsct}asdthe5u&astreum(ddr30 u/scl{anddba€uliemlreequabcnr.. • leaf Contaatr ll?Ao79aanq¢5ofl(pU74WSMMscfiiay tXVS4453111h uof/day5n.ff2Vt8:996Yihnan.qPinaanci9Mhhsfilday}/{6.9H314S53MMsofl yearly;htatiapudaddlpigaswo Idba ISu) ire} hII wa::H4aG InpuG(MMOtu rf''(PA&37:A$53MMsaf/dapP(355day/year)°;24468 iiftmi©wacd:Ct}'enilssi fit Ne talus latedatra:-0#tpy.amf.$E&tpy:respactiyer. fb0awin egimttan toralcpuf:(MM9kuhr atifn uldrolladtitClCitonlyr)i`C2L7D0IbR nfytMWdbilbdate "[iT sefl8"ikMn49tt/t , Fmf'ehnoyera„t§q#tdhaS yide:fNa:daantvoluasuseditythisiegantioa„hawevaritheuper.t provfin/itwlaatata aihHd$`gimaconsematfu tb tha a Iboowlpulob d be eahgpreocdbedisiethudk:IGedills'ysedOts'permimnme° p ppiludiire,ihn tperarorIntarrectlyspxelfiedtltef9#hryiounades°'b teadtoon urderestimaterofd()C,Assuciatheapemtarupdaeed₹1fmsimnletianfie "4LherOenaosre camps. ptahlesIncetheeamporentwasrarrecdyspecgiddaspa;heseneratiterihaeahmata: . , . . . . atnuladonasedtadstabddidieddd•udpedideipispioaddenaa,itwasdeterminadtheopitatrowaaastaaairaddatepfaasaioadf1hdiand end;fveathingafnissiunu'asso0atedwithh-Nissoueadilheoperatnrwaonntdledofthis asoe;As%eresubothetnuf arsimWagoovms.oydut .. o.._ "--_ thetanittass stencii'3n mdermaccaratelyestimatewo,&iilgattd treactang enasionu. theapplt4ation,there adesideen(1615361t06fued faol!sto g%ieuelsand.one;il300bblftxed roof storageyesseL.5tnce themaioorbeithestatagevewekhayearapachy of 53nbbb,the teainMsx.utilioast?edlmetsinnssftbaS36bbintvageue;sets,T nioasdeemed'approprtato becausetheemjotityofthastorageamrat?raue the largerccpadty and as a ravel.the Pau uotput will 'Maly bepracessadbythaasoetsle -- - - aca;Tftigwasr oRingth bbutNemostcunent 1 a addlttastabidhamissiones#attore#knthissemaewa addaaiaedadthluayearaffireapPltddlaa aaaa1dPid.dau6taisredAda1.Ire&uwu2af d2l.wallanA7/105110717;fila theeghenewweifs.ddlitddttM5facilhy. tiva.mnityxttegerma'weiooOeequirueinbfaltestmginardertoobtalaasitespuenitesatr, to &Taepaemennll'nconned I inhiaf rpedadlenpacdytrei. gf itself reberausetheo&epianappmved₹or IbiesooreeIrequirssdailyvisdti soE .7Ake'cwetatars+asgmvidedwittyadra[tpefmihtarey wpri0t'.:. `subltttludddlu 115ofSt niipbe.remnyedttt4hdrequestwasagr peatpraxpremedtN0p.f18dnugti rvwariertsunthedtaft,": Section 09 -Inventory SCC Coding and Emissions Factors AIRS Point # Process # SCC Code 001 01 ra dtaf#andprovidedanecommeno,Theoperatorreques~edco tVace:"Fxrmik#artdttkmb regarding iced,dnec405farthestpmgetadfcan 12/TO/2012)andpeovided a copyefthasgftmittaL3hc Uncontrolled Emissions Pollutant Factor Control% Units PM10 0.00 0 b/1,000 gallons condensate throughput PM25 0.00 0 b/1,000 gallons condensate throughput NC% 0.200 0 6/1,000 gallons condenssetlu0ughput VOC 69.14 95 b/1A00 gallons condensate -throughput CO 0.559 0 b/1,000 gallons condensatethmughpid Benzene 0.1690 95 b/1,000 gallons condensate throughput Toluene 0.2375 95 b/1p00 gallons condensatethroughput Eshylbenzene 0.0072 95 b/1,000 gallons condensatethroughput Xylene 0.0991 95 b/1,000 gallons condensate throughput n -Reran 1.5461 95 b/1,000 gallons condensate throughput 224TMP 0.0094 95 b/1,000 gallons condensate throughput 3 of 5 Ki\PA\2017\17WE0772.CP1.xlsm Condensate Tank Regulatory Analys)s Worksheet Colorado Re- latter 3 Parts A and B - APEN and Permit Requirements 'you have Indicated that nourcc le in she Non.Arainment Area ATTAINMENT • . 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part?, Section ll.D.1.a)7 2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than SOTPY or CO emissions greater than 10 TPY (Regulation 3, Part 0, Section 11.1.3)? 'You 11120 hndlroted the: source is in the Non -A aimnor,t0Mn - NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II D.1.a)? 2. Is the construction date (service date) prior to 12/30/2001 and not modified after 12/31/2002 (See PS Memo 05 -01 Definitions 112 and114 and Section R for additional guidance on grandfather applicability)? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOg greater than 5TPY or CO emissions greater than 5TPV (Regulation 3, Part B, Section R.D.2)? ' 'Sodreereslslres a penult Colorado Regulation 7, Section %II.C.F - 1. Is this storage tank located In the 0 -hr ozone control area or any ozone non -attainment area or attalnment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? IStorape tank Is sublect to Regulation 7, Section %I .C -F Section 011.[.1 —General Requirements for Ale PollutionControl Equipment —Prevention of Leakage • Section 011.03 —Emission Estimation Procedures Section %11.0 —Emissions Control Requirements Section )(ILE— Monitoring Section t01.F—Recordkeeping and Reporting Colorado Regulation 7. Section 011.6 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 thls storage tank located ate natural gas processing plant? 3. Does this storage tank exhibit"Flash" leg. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VIC? 'Storage Tank is not.nohjole to Regulation 7. Section Ni1.G Section 010.0.2- Emissions Control Requirements Section %II.C.1 —General Requirements for Alr Pollution Control Equipment —Prevention of Leakage Section %II.C,2—Emission Estimation Procedures Colorado Reacletioh 7, Section %VII 1. Is this tank located eta transmission/storage faclllty? 2. Is this condensate storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor station' or natural gas processing plant? 3. Is this condensate storage tank a fixed roof storage tank? 4. Are uncontrolled actual emissions' of this storage tank equal to or greater than 6 tons per year VOC? '"Storage tank Issubject to Ret'ulatiorr 7, Suction KV€i, R, 1.1 & C.9 Section tVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emission Section OVII.C.1- Emissions Control and Monitoring Provision Section trVll,CS-Recordkeeping Requirements Does the condensate storage tank contain only "stabilized" liquids? 'Senate rank tn.subject to Regulation 7. Suction XVR.C,2 Section tcVII.C.2 - Capture and Monitoring for Storage Tanks fined with Air Pollution Control Equipment 40 CFR, Part 60, Subvert Rh, Standards of Performance for Volatile °ramp MOM Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (me) (-412 BBLs)? 2. Does the storage vessel meet the following exemption In 60111b(df(4)? a. Does the vessel has a design capacity less than or equal to 1,589.874 me I"1o,000 BBL) used for petroleum' or condensate stored, processed, orheated prior to custody transfer' as defined in 60.1115? 3. Was this condensate storage tank constructed,reconstructed, or modified (see definition 40 CFR, 60.2) after holy 23, 1904? 4. Does the tank meet the definition of "storage vessel' In 60.1116? 5. Does the storage vessel store a"volatile organic ligoid(VOL("5 as defined In 60.111b? 6. Does the storage vessel meet any one of the following additional exemptions: e. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa r29.1 pal] and without emissions to the atmosphere (60.11obld)(2))?; or b. The design capacity is great,n than or equal to 151 m'(-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 greaterthan or equal to 75 Ma (-472 BBL] but less than 151 m' ["950 BBL] and stores a liquid with a maximum true vapor pressure° less than 15.0 knai60.11Db(b)(? 'Storage Tank In not subinat to N5(5 Kb Subpart A, General Provisions 460.1126• Emission Control Standards for VOC 460.1136 -Testing and Procedures 460.115b - Reporting and Recordkeeping Requirements 460.1166 - Monitoring of Operations 40 CPR. Part 60. Subpart 0000. Standards of Performance for [rude Oil and Natural Ras Production, Tansmlulan and Distribution 1. Is thls condensate storage vessel located at 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 thls condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR,00.2) between August 23, 2011 and September 10, 2015? 3. Are potential VOC emission' from the individual storage vessel greater than or equal to 6 ton per year? 4. owes this condenate storage vessel meet the definition of 'stomp vessel"' Per 60.5430? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part605ub art Kb or 40 CFR Pan 63 Sub art NR? 'Storage Tank is not subject to NSF500000 Subpart A, General Provision per 460.5425 Table 3 §60.5395 - Emission Control Standards for VOC - 460.5413 - Testing and Procedures • ' §60.5395(8) - Notification, Reporting and Recordkeeping Requirements 460.5416(c)- Cover and Closed Vent System Monitoring Requirements 460.5417- Control Device Monitoring Requirements - [Note: de storage vessells previously determined to be subject to NSPS 0000 due to emission above 6 tons per year VOL on the applicability determination date, It should remain subject to NIPS 0000 per 60.5365(e)(2) even If potential VOC emission drop below 6 tan per year) S`n5 Paw MEM yes Yes Yea , r Yen Na No Source Requires an APEN. Ge to the next question Go to next question Source Requires a permit Continue You have Indicated the site attainment status on the project summary sheet. Continue- You have Indicated the facility type on the project summary sheet. Source Is subject Continue - You have determined facility attainmentstatus on the Project Summary sheet. Storage Tank In not subject to Regulation 7, Section%II.G - You have indicated facility type on project summary sheet. Continue- You have Indicted 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.6&1. Go to the next question Source Is subject to all provision of Regulation 7, Section B & C Go to the nett question Storage Tank is not subject NIPS Kb. Ye: Continue - You have Indicated the source category on the Project Summary sheet. Storage Tank Is not subject NSP5 0000 -This tank was contracted prior to or after the applicability date. 40 CFR, Part fin. Subpart 00005, Standards of performance for Crude Oil and Natural Gas Facilities for which Construction Modification. or Reconstruction Commenced Aker September 00. 2015 L Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after September is, 2015? 2. Does this condensate storage vessel meet the definition of "storage vessel" per 60.5430a? 3. is this condensate storage vessel located ate facility In the crudeall and natural gas production segment, natural gas processing segment or natural ass ...stoles,.and storage segment of the industry? 4. Are potential Von emissionsfrom the lndlvidualietorega vessel&&`eater than or equal 4,6 tons per year? 5. Is the storage vessel subject to and controlled In accordance with requirements forstarage vessels In 40 CFR Part 60 Subpart Kb or40 CFR Part 63 Subpart HH? IStoinge yank is not subject to NSPS 0000' 40 CFR. Part 63, Subpart MAC' HH. OII and Gas Production Facilities L Is the storage tank located at en oil and natural gas production facility that meets either of the following criteria: a. *facility that processes, upgrades or stores hydrocarbon liquids' (63.760(')(2)); OR b. A facility thatprocesses, upgrades or stares 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 user' (63.760(a)lall? 2. Is the tank located ate 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. S. Is the tank subiect to control requirements under40 CFR Part 60, Subpart Kb or Subpart 00007 'Storage Tack iv tiot st:h)e0T toh?ACT 110' Subpart A, General provisions per463.764 (a) Table 2 463.766- Emissions Control Standards 463.77e' Monitoring 463.774- Recordkeeping §63.775 -Reporting RACr Review PACT review is required if Regulation 7 does not apply AND If the tank is in the non -attainment area. If the tank meets bath 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 particulars/Motion based upon the individual facts and circumstances. This document does not change or substitute for any law, regulatloh, or any other legally bind/n0 requirement and is not legally enforceable. In the event of anyconm'ct between the language of lies daemon( And (M@ IAng0A9@ pull@ Glean Air A.ct„ Ifs 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 APCQ interpretations and recommendations. Mandatory terminology such as'mile and 'required' are Intended to describe controlling requirements under the terms of the Clean Air Act andAlr Quality Control Commission regulations, but this document does not establish legally binding requirements in and of Itself. GO to the next question . Go Lathe next question Go to the nOM question Storage Tank is not acblect NSPS 0000a. Yes (Continue- You haveindlrated the source category on the Project Summary sheet. WEE Storage Tank is not subject MAR HH-There are no MAC? HI requirements for tanks at area sources ©t Division h b Environment CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0772 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Brown 23 Sec HZ; 23-43 123/4427 SWSE SEC 23 T5N R65W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 001 Sixteen (16) 538 barrel and one (1) 300 barrel fixed roof condensate storage vessels connected via liquid manifold. Enclosed Combustors This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. 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 operators 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. ) This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date: The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) COLORADO Pollution Control Division 3. The •. ;er all c: ete itial °mpliance testing and sampling as required in this permit as part of the self -certification process. (Regulation 4. op it re •erm' _ =al authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) .A.4. ) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO TK-1 001 --- 5.4 65.8 10.7 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. 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 TK-1 001 Enclosed Combustors (Eight (8) Cimarron 48" and one (1) Cimarron 60") VOC and HAP 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 rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 001 Condensate throughput 905,262 barrels The owner or operator shall monitor monthly process rates based on the calendar month. COLORADO jl Air 'Pollution Control Division lAr_me tt ur Pubrez. HetIttit& ewfr-onment Page 2 of 7 imits shall be determined on a rolling twelve (12) month twelve-month total is calculated based on the previous shall calculate throughput each month and keep a eld office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. 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) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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) 11. 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. 12. 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. 13. 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 E: MAINTENANCE REQUIREMENTS 14. 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.) COLORADO Air Pollution Control Division 1 ..kpce,re ent 4P Pbuic .£ h v Ez^11 onns@kf Page 3 of 7 15. Four - is •t quirt, to onduct i' fiat testing, unless otherwise directed by the Division or o er sta a or e•eral requirement. Periodic Testing Requirements 16. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 17. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or 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. 18. The requirements of Colorado Regulation Number 3, Part D shall apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 20. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the COLORADO Air Pollution Control Division ivat, Heklth E`-a6Lrit ell Page 4 of 7 in writing in accordance with the provisions of 25-7- n Number 3, Part B, Section III.G. Final authorization activity commences andhas been verified by the APCD onditions of the permit. Once self -certification of all oints h .ee -view-a n :'•prov •y 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: Harrison Slaughter Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Permit for condensate storage vessels at a synthetic minor facility. COLORADO Air Pollution Control Division Dep r*Ae t of Public Health n E_':rvorrtt•+ t Page 5 of 7 Notes per t issuance: 1) Th per h d �, is reE to • y -es f. the processing time for this permit. An invoice for these f- wile i ue •ft; the. a is issu-; . The permit holder shall pay the invoice within 30 days to p e 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-reps 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) 001 Benzene 71432 6,426 322 Toluene 108883 9,029 452 Ethylbenzene 100414 273 14 Xylenes 1330207 3,767 189 n -Hexane 110543 58,785 2940 2,2,4- Trimethylpentane 540841 359 18 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 1.18x10-2 1.18x1072 TNRCC CO 2.35x10-2 2.35x10-2 TNRCC V0C 2.904 1.452x10-1 ProMax 71432 Benzene 7.098x10-3 3.55x10-4 ProMax 108883 Toluene 9.97x103 4.99x10-4 ProMax 100414 Ethylbenzene 3.01x10-4 1.50x10-5 ProMax 1330207 Xylene 4-16x10-3 2.08x1O4 ProMax 110543 n -Hexane 6.49x10-2 3.247x10-3 ProMax 540841 2'2'4 Trimethylpentane 3.96x1O4 1.98x1O5 ProMax COLORADO Air Pollution Control Division pot -sent of FtsbEz iieG �^-i E:^vir rv=ter.. Page 6 of 7 point are based on the enclosed combustor control efficiency .1, eac it Pollutant Emission Notice (APEN) associated with year •m the date it was received by the Division. A revised APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC, n -Hexane, and Total HAPs NANSR Synthetic Minor Source of: VOC PSD True Minor MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below:. http://ecfr.gpoaccess.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1 -End Subpart A - Subpart KKKK NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ - Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980 -End Subpart NNNNN - Subpart XXXXXX COLORADO Air Pollution Control Division 6 'avBon ier c Page 7 of 7 Condensate Storage Tank(s) APEN - Form APCD-205 O��1 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN--- updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source (e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loadings, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration 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: l7 tNE0772 AIRS ID Number: 123 / 4427 /001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Brown 23 Sec HZ; 23-43 Site Location: SWSE Sec 23 T5N R65W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Jack Starr Phone Number: (303) 860-5800 E -Mail Address2: Jack.Starr@pdce.com 1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 366��2 Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 1 I AI,, DP COLORADO Permit Number: 1-WIO1-V2 AIRS ID Number: 123 / 4427 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2 - Requested Action ✓❑ NEW permit OR newly -reported emission source ✓❑ Request coverage under traditional construction permit O Request coverage under a General Permit ❑ GP01 O GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment O Change company name ❑ Change permit limit O Transfer of ownership3 O Other (describe below) -OR- ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ APEN submittal for permit exempt/grandfathered source Additional Info Et Notes: Eight (8) new well additions added to previously permitted facility; Additional equipment added to location; request a change of permit coverage from General Permit (GP -01) to construction permit 3 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Storage Tanks For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 Storage tank(s) located at: 1/15/2003 hours/day 7 days/week 52 weeks/year ❑✓ Exploration & Production (MP) site O Midstream or Downstream (non EtP) site Will this equipment be operated in any NAAQS nonattainment area? SI Yes ■ No Are Flash Emissions anticipated from these storage tanks? IS Yes ■ No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? IS Yes ■ No If "yes", identify the stock tank gas -to -oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)SI 805 series rules? If so, submit Form APCD-105. Yes No ■ Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual emissions ≥ 6 ton/yr (per storage tank)? Yes No O ■ Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 ; Department of Pubilc COLORADO s KI u,n.aunenl Permit Number: 1-4--uce AIRS ID Number: 123 / 4427 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/year) Condensate Throughput: 905,262 905,262 From what year is the actual annual amount? 2017 Average API gravity of sales oil: 50.5 degrees 0 Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 8.1 0 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 17 8908 11/2016 1/2003 Wells Serviced by this Storage Tank or Tank Battery5 (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123- 20441 Brown 23-43 ■ 05 - 123- 42660 Brown 23D-201 • 05 - 123- 42659 Brown 23D-341 05 - 123- 42656 Brown 23D-421 0 05 - 123- 42661 Brown 23P-201 0 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EEtP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.380434 / -104.626175 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal 0 Downward 0 Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): 0 Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 3 I A COLORADO of PubLic Permit Number: ►-1- (.0601-3-2, AIRS ID Number: 123 /4427 / 001 [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Vapor ❑ Recovery Unit (VRU): Pollutants Controlled: Size: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: % ❑ Combustion Device: Pollutants Controlled: Rating: Type: VOC, HAPs, BTEX Enclosed Combustor MMBtu/hr Make/Model: 8 x Cimarron 48", 1 x Cimarron 60" Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Constant Pilot Light: ✓❑ Yes O No Pilot Burner Rating: Btu/scf MMBtu/hr O Closed Loop System Description of the closed loop system: O Other: Pollutants Controlled: Description: Control Efficiency Requested: Section 7 -Gas/Liquids Separation Technology Information (E&P Sites Only) What is the pre- Ire of the final separator vessel prior to discharge to the storage tank(s)? 36 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator COLORADO Form APCD-205 - Condensate Storage ani:(s) /PEN - Revision 02/2017 4 I �� N°`""<R`"6".°'"f".17,;,:::•-•=, Permit Number: AIRS ID Number: 123 / 4427 / 001 [Leave blank unless APCD has already assigned a permit r and AIRS ID} Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC Enclosed Combustor 95% NOx CO HAPs Enclosed Combustor 95% Other: From what year is the following reported actual annual emissions data? 2017 Criteria Pollutant Emissions Inventory Pollutant Emission Factor6 Actual Annual Emissions Requested Annual Permit Emission Limit(s)4 Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Tons/year) (Tons/ ear Controlled - Emissions7 (Tons/year) Uncontrolled Emissions Tons/ ear (Tons/year) ) Controlled Emissions Tons/ ear (Tons/year) ) VOC 2.w`( lb/bbl ProMax (7j\ -1 3 loS.'12 ‘'.6\i -t..1 1n5. -I2 NOx 0.1380 Ib/MMBtu TCEQ N/A N/A 4-955.5,3] 4.9,; 5;3 CO 0.2755 Ib/MMBtu TCEQ N/A .97871O,k0-6 N/A •9.8- Ip, C Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract (CAS) Service CAS Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) Uncontrolled Emissions (Pounds/year) Controlled Emissions7 (Pounds/year) Benzene 71432 1.0AS )cto3 lb/bbl ProMax to,42 0 312 - Toluene 108883 9.g1-x►o 3 lb/bbl ProMax 9,O29 452 Ethylbenzene 100414 3,•pl )(to i lb/bbl ProMax 243 ly Xylene 1330207 l-(.► ))06 3 lb/bbl ProMax 3,3-0- l SI n -Hexane 110543 b.(4°vI6 lb/bbl ProMax S$11 -SS 2,`1yO 2,2,4- Trimethylpentane 540841 - 32gtz) w y lb/bbl ProMax 3S1 \s 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. 7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. W1/4c$ ?or cc tiCG.C)A-co\ C \&A • tfDb 1-111-1/11- FormAPCD-205 - Condensate Storage Tank(s) AFEN - Revision 02/2017 COLORADO 5ubbc - :t rme Department b Envtonm.nf Permit Number: LJC,03-3-7-- AIRS ID Number: 123 /4427 / 001 [Leave blank unless APCD has already assigned a permit A and AIRS ID] Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. �gnature of Legally Authorized Person (not a vendor or consultant) Jack Starr 2-O 2O Date EHS Professional Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance ✓❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250, if applicable, to: Colorado Department of Public He=,'`h and Environment Air Pollution Control Division APCD-SS-B 1 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-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 ®� COLORADO nn,n-cn‘,=, E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: PDC Energy, Inc. Source Name: Brown 23 Sec HZ; 23-43 Emissions Source AIRS ID2: 123 / 4427 / 001 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-42657 Brown 23P-221 // 05 - 123 - 42681 Brown 23P-321 /1 05 -123 - 42655 Brown 23X-241 // 05 -123 - 42658 Brown 23X-341 // - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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 Addendum Hello