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Home My WebLink About20183138.tiffCOLORADO Department of Public Health Et Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 11500 St PO Box 758 Greeley, CO 80632 September 19, 2018 Dear Sir or Madam: RECEIVED SEP 2 5 2018 WELD COUNTY COMMIS CNFn ; On September 20, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Jacobucci 32 Sec Pad 3. 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 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Public R v;ew (0/S/18' c c. PLCTP), Pc '(ER /C H/ 3'm I C K), HLCJT) `'i (9-7/14e 2018-3138 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Jacobucci 32 Sec Pad 3 - Weld County Notice Period Begins: September 20, 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: Jacobucci 32 Sec Pad 3 Well Production Facility NWSE SEC 32 T1 N R67W Weld County The proposed project or activity is as follows: Condensate Storage Tanks The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area) The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE0585 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: Timothy Sharp 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 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details ReviewEngineer. "fimotf4y5hacp � . Package#: 363535�� - � � Received Date: sJ4Jza19�� . Review Start Date: 11/o7f2cY7 Section 01-Facility Information Company NamE: POLEr�er�y�� quadrant Section Township Range CountyAIRSID: YZ3. �� -� Weld .� NW3E 32 �. iN �,�,;,67-� PlantAIRSID: 9F2F '- facility Name: Jacobucci�32 Pad 3 � �� - � �� Physical Address/Locatio NWSE quadrant of Sedion 32,Township 1N,Range 67W,in Weld County,Colorado . Type of Facility: �xplocation-&FeadustPor�WeltFad � �'�.. What industry segment?D3i&NaturaIv^as Prfldvc₹�on&Protesvng '� Is this facility located in a NAAQS�non-attainment area� ��.�.- Yes �� If yes,for what pollutant? [�arbon Mononde(CO) [I}articulate Matter(PM) [�zone(NOx&VOC) Section 02-Emissi�ons Units In Permit Application Emissions Seff Cert Engineering AIRs Point t! Emissions Source Type Equipment Name Permit# Issuance# Action CoMrol? Required? Remarics Permtt Inifi�al �-�.061 Gande�sateTank Yes 17we0585 1 Yes.. :- Issuance Section 03-Description of Project Section 04-Public Comment Requirements Is Public Comment Required? '� Yes '� If yes,why? Req�esqng Syntkretic Minar Petm'rt:_� ..... .. ..'. ____ _.._. _:_ __.._ _ _.. .___ __; Section OS-Ambient Air Impact Analysis Requirement: Was a quantitative modeling analysis required? 'Cdo If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-FaciliTy-Wide Stationary Source Classification - Is this stationary source a true minor? , i�a Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: so2 Nox co voc PM2.5 PMSO TSa HAPs Prevention of Significant Deterioration(PSD) � ❑ Q Q� � ❑ Title V Operating Permits(OP) ❑ ❑ Q Q Q [f ❑ ❑ Non-Attainment New Source Review(NANSR) ❑ Q Is this stationary source a major source? If yes,explain what programs and which pollutants here 502 Nox co voc PMz.s PM10 TSP HAPs Prevention of Signifcant Deterioration(PSD) � Q ❑ [] Q � Title V Operating Permits(OP) [� Q [g �j ❑ [� ❑ [� Non-Attainment M�w Source Review(NANSR) Q ��. Condensate Storage Tank(s)Emissions Inven₹ory Sec[ion Ol-Administredive Information FacilityAlRsID: �' � � , ,,,,,,,�� ''�. ...,,.. �f ,,,,,.,��. �,.,,,.:, :�''�. County Plant Point � - Sec[ion 02-Eouioment Descriotian Details Detailed Emiss s Un t I2xRfT bbl(4$0�6bEtok3[�attely ,; � y � _ , ,,,,tt�33j333 3 � - Descnption. :; -- " ` . ---' � , „,,,,,,, „,�„ ,,,, , ,,,��,., .; �,; ) � � Em ss on Controi Devi ce �pE.$pqp(�g61i1bU5bun deviCe - . Descr Pt on: � ,3; ..�� ."�ll.a,3�;3°t.,,,.. � a P ._ ,, ,.,- ,, Requested Overall VOC&HAP Control - ��'� � E�ciency%: � 95, � � Section 03-Processine Rate Information for Emissions Es[imates Primary Emissions-Starage Tank(s) Actual Condensate Thraughput= >o,7fi2.Earrels(6b1)per year Actual Condensate Throughput While Emissons Controls Operating= : 75f>,75F:Barrels(6hl)peryear RequestedPermitLimitThroughput= ��.796,76L:3arrels(bbl)peryear Potential to Emit(PTE)Condensate Throughput _ �'9[3,Z14i earrels(b6p per year Secondary Emissions-Combustion Device�s) � Heai content of waste�s= 10V6��.8tu/scf Volume of waste gas eraitted per BBL of I iqu ds praduced= '�.scf/661 Actual heat content of waste gas rou[ed to wmbustion devlce- � 75,276 MMBTU per year ftequested heat content of waste gas routed io combustion device= 75,276 MMBTU per year Porential to Emit(PTE)heat content of waste gas routed to com6ustion device= 90,331 MMBTU per year Section 04-Emissions Factars&Methodoloeies -a / Willthisstoregetankemitflashemissions? Yes ,_ EmissionFactors CondensateTank � Uncontralled Controlled Pollutant (16/661) (Ih/661) EmissionFactor5ource , . (Condensate (Condensate Throughput) Throughput) VOC 3:33 ? 0.17 � . Benzene f3A07-: 0.000 Toluene i3.0i36��. 0.000 -- Ethylbenzene q.o�a�: 0.000 �� j � � � Xylene O.I703�:�� 0.000 � .;�'�}, '; .�,6 n-Hexane 0.059� 0.003 � 224TMP �.OUO��:�� 0.000 ,,,:��.;... ::�� '� � Controi Device � Uncontrolled Unconirolled Pollutant (Ib/MMetu) (16/661) EmissionFactor5ource ' (waste heat (Condensate om6i�sied) Throughpu4) PM10 0.0000 ^� � PM2.5 o.00ao �� f?:, „i„',�,�� NOx �.t38C: 0.0000 3bfE2�Et3are�ssroe3s��;q(dxee{i1t<i, co o.z�ss� aaaoo �RC��Iaxe�r.a�ts,�t�a3da�ce:c¢ Section OS-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Criteria Pollutants Umm�trolied Unrontrolled Controlled Umm�irolled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) VOC 1538.0 1281.7 64.1 1281.7 64.1 PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 0.0 0.� � NOx 6.2 5.2 5.2 SZ SZ CO 12.4 l�.q 14A 10.4 1�.4 Potential to Emit Actual Emissions Requested Permit Limits HazardousAirPollutants Uncontrolled Umm�trolled Conirolled Uncontrolled Controlled Qbs/year) (Ibs/year) Qbs/year) (16s/year) (16s/year) Benzene 6084 5070 254 5070 254 Toluene 4995 4162 208 4162 20S � Ethylbenzene 363 303 15 303 15 Xyiene 2452 2043 .1�2 2043 102 n-Hexane 53125 44271 2214 44271 2214 224TMP 363 303 15 303 15 Section 06-Re¢ulatory Summary Analysis Regulation 3,Parts A,B Source requires a Rermit Regulation 7,Section X[LC,D,E,F Storage[ank is subject to Regulation 7,Se<tion XILGF Regula[ion 7,Section XII.G,C Storage Tank is not su6ject to Regufatiun 7,5ection XII.G Regulation 7,Sec[ion XVII.B,C.1,C3 Storage tank is subject to Regulation 7,Section XVII,B,CS&C,3 - Regulation7,Sec[ionXVILCI StoregetankissubjecttoRegulation7,5ectionXVu.G2- Regulation 6,Part A,NSPS Su6part K6 Storage Tank is not subject to NSPS Kb Regulation 6,Part A,NSPS Subpart 0000 Storage Tank is not su6jec[to NSPS 0000 Regulation 8,Part E,MACT Subpart HH Storage Tank is not subject to MACT HH � (See regulatory applicability worksheet for detailed analysis) 3 of4 C:\Users\tsharp\Desktop\PA_17WEOSSS.CPl.xlsm Condensate Storage Tank{s}Emissions Inventory Sestian 07-Initial and Periodic5amolin¢and Testine Renuirements fl��'� �oes the campany use the state default emiss ons factors to estimate em�ssions? -- - _ If yes,are the unrontrolled actual or requested emiss ons estimated ta be greater than or equal to�80 tons VOC per year? ,_ If yes,the permit will contain an"Initial Compliance"testing requirementto develop a site specific emissions factor based on guidelines in PS Memo 0S-01. '�y��- .=.�y`;§ � Does the company use a site specific emissions factor to esnmate emissions? � ' �' ' � �,��%%� If yes and ithere are flash em ssions,are the emissionsfacrors based on a pressunzed liquid sample drawn at the � - f' � facility 6e ng perm tted�This sample should be considered representat ve wh ch generally means site specific and ��„ � � mllected wrth n one year of ihe application rece ved date.However,if the faaliry has not been modif ed(e.g.,no ,�„» � ₹-,i new welis 6rought on-line�,then it may he appropriate to use an older s te-spenfc sample. .f "� ,,,,,..; _ ..r -� ; If no,the permit will mntain an"Initial Compliance"testing requirement to develop a site specific emissionsfactor 6ased on guidelines in PS Memo 0S-0L Does the rompany request a mntrol device effinency greater than 95°6 for a flare or combustion device? �S..��s��,H,_,_,��j,; If yes,the permit will contain and initial complian<e test condition to demonstrate the destruction efficiency of the comhustion device based on inlet and outlet conceniration sampling Sec2ion 0&-Techn ca�l A�aly sr is Notes Section 09-Inventory SCC Codin¢and Emissions Fac[ors Uncontrolled Emissions AIRSPoint# Processq SCCCode Pollutant Factor Control% Units ,. . 001 Ol ��fh��„ G "�✓j"�.,��jf,D,,,�s„,�,y fi„s�,,,,,��:»«.»,ti€'s PM10 0.00 0 Ib/1,000gallonscondensatethroughput PM2.5 0.00 0 Ib/1,000gallonscondensatethroughput NOx 0.33 0 Ih/1,000gallonscondensatethroughput VOC 80.7 95 Ib/1,000gallons<ondensatethroughput CO 0.65 0 Ib/1,000gallonsmndensatethroughput eenzene 0.16 95 Ib/1,000gallonscondensatethroughput Toluene 0.13 95 Ih/1,000gallonsmndensatethroughput Ethylbenzene 0.01 95 Ib/1,000gallonscondensatethroughput � Xylene 0.06 95 Ib/1,000gallonscondensatethroughput n-Hexane 1.39 95 Ib/1,000gallonscondensatethroughput 224 TMP � 0.01 95 Ib/1,000 gallons condensate throughput 4of4 C:\Users\tsharp\Desktop\PA 17WE0585.CPl.xlsm Permit number: Date issued: issued to: COL RADO Air Pollution Control Division Department of Public Health 8 Environment CONSTRUCTION PERMIT 17WE0585 DRAFT Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Jacobucci 32 Sec Pad 3 123/9F2F NWSE SEC 32 T1 N R67W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description Condensate Tanks 001 Twelve (12) 400 barrel fixed roof storage vessels used to store condensate oil Enclosed Flare This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION 1. YOU MUST notify the Air Pollution Control Division (the Division) no later than fifteen days of the latter of commencement of operation or issuance of this permit, by submitting a Notice of Startup form to the Division for the equipment covered by this permit. The Notice of Startup form may be downloaded online at www.colorado.gov/pacific/cdphe/other-air-permitting- notices. Failure to notify the Division of startup of the permitted source is a violation of Air Quality Control Commission (AQCC) Regulation Number 3, Part B, Section III.G.1. and can result in the revocation of the permit. 2. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit shall be demonstrated to the Division. It is the owner or operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.gov/pacific/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) COLORADO Air Pollution Control Division Page 1 of 7 3. This permit shall expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NOX VOC CO Condensate Tanks 001 --- 5.2 64.1 10.4 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual 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 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 Condensate Tanks 001 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit Condensate Tanks 001 Condensate throughput 756,762 barrels COLORADO Air Pollution Control Division Page 2 of 7 The owner or operator shall monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) shall be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (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 Et MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator shall follow the most recent operating and maintenance (O&M) plan and record keeping format approved by the Division, in order to COLORADO Air Pollution Control Division Page 3 of 7 demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to the OEtM 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, Sections XII.C, 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 (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 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. COLORADO Pollution Control Division Page 4 of 7 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. By: Timothy Sharp Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division 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/agcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 5095 255 Toluene 108883 4166 208 Ethylbenzene 100414 293 15 Xylenes 1330207 2010 101 n -Hexane 110543 44273 2214 2,2,4- Trimethylpentane 540841 294 15 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 NOx 0.1380 lb/MMBtu TCEQ CO 0.2755 lb/MMBtu TCEQ VOC 3.3873 Source ProMax 71432 Benzene 0.0067 Source ProMax 108883 Toluene 0.0055 Source ProMax 100414 Ethylbenzene 0.0004 Source ProMax 1330207 Xylene 0.0027 Source ProMax 110543 n -Hexane 0.0585 Source ProMax COLORADO Air Pollution Control Divi Page 6 of 7 CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 540841 2, Trimethylpentane 0.0004 0.0004 Source 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 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, HAPs PSD or NANSR Synthetic Minor Source of: VOC 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 COL RADO Air Pollution. Control Division Page 7 of 7 Condensate Storage Tank(s) APFNi Form APCD-205 Air Pollutant Emission Notice (APEN) and. Application for Construction Permit All sections of this APEN and application must be completed for both new and existing fac es, updates. An application with missing information may be determined incomplete and may b e longer application processing times. You may be charged an additional APEN fee if the APEN is f 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 yourmission 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: 5FJg� AIRS ID Number: tZ3 /gF2F [Leave bank un Less APCD has Dreads a.,_ _Ine a a l"'li_ ? and FIRS 01 Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Jacobucci 32 Sec Pad 3 Site Location:, NWSE Sec 32 Ti N R67W 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. Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 COLORADO Mew Permit Number: AIRS ID Number: [Leave blank unless A'.PCD has already E.S.27ied 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 ❑ 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) O Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership' ❑ 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: Initial permit request for new facility 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: hours/day 3/13/2017 7 ❑✓ Exploration a Production (EEtP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EaP) site Will this equipment be operated in any NAAQS nonattainment area? Yes ❑ No ✓ Are Flash Emissions anticipated from these storage tanks? Yes No ■ • Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 12 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) 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 0 ■ Form APCD-205 - Condensate Storage T ank(s) APEN - Revision 02/2017 2I m� [X,runcritc, Pub, COLORADO e crr..enn,en. Permit Number: AIRS ID Number: [Lea, _„a!h urdless APCD has already a _need a permit arlfl L.IRS ID1 Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/ year) Condensate Throughput: 756,762 756,762 From what year is the actual annual amount? 2017 Average API gravity of sales oil: 44.6 degrees ❑ Internal floating roof Tank design: ❑✓ Fixed roof RVP of sales oil: 8.5 ❑ 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 12 4800 9/2016 3/2017 Wells Serviced by this Storage Tank or Tank Battery5 (EEtP Sites Ony) API Number Name of Well Newly Reported Well 05 - 123- 41941 Jacobucci 32S-203 O 05 - 123- 41942 Jacobucci 32S-303 IS 05 - 123- 41940 Jacobucci 32S-323 HI 05 - 123. 41944 Jacobucci 32S-343 O 05 - 123- 41943 Jacobucci 32S-403 SI 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The EaP 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) 40.006975 / -104.917306 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 ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular ❑ Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD-205 - Condensate Storage Tank(s) APED' - Revision 02/2017 3 I A COLORADO e uv. eP thtiN Permit Number: AIRS ID Number: / / [Leave biacck unless APCD Les a',ready a_ a permit. __ad AIRS ID) Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Vapor ❑ Recovery Unit (VRU): Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): ❑ Combustion Device: Pollutants Controlled: VOC, HAPs, BTEX Rating: MMBtu/hr 4 x Cimarron 48", 1 x Cimarron 60" Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 % Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: Waste Gas Heat Content: Btu/scf MMBtu/hr ❑ Closed Loop System Description of the closed loop system: ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: % Section 7 -Gas/Liquids Separation Technology Information (EEtP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 30 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator 1 Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017 4 COLORADO Permit Number: AIRS ID Number: [Leave blank unle_s ' p13 has already assi:nsd a permit = and AIRS iD Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form6. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall ( Pollutant Description of Control Method(s) Overall Requested Control Efficiency (% reduction in emissions) VOC 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) Controlled Emissions7 (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 3.3873 lb/bbl ProMax 1281.69 64.08 1281.69 64.08 NOx 0.1380 lb/MMBtu TCEQ N/A 5.19 N/A 5.19 CO 0.2755 lb/MMBtu TCEQ N/A 10.37 N/A 10.37 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, etc) . g Uncontrolled Emissions (Pounds/ ear y ) Controlled Emissions7 (Pounds/year) Benzene 71432 0.0067 lb/bbl ProMax 5094.85 254.74 Toluene 108883 0.0055 lb/bbl ProMax 4165.58 208.28 Ethylbenzene 100414 0.0004 lb/bbl ProMax 293.20 14.66 Xylene 1330207 0.0027 lb/bbl ProMax 2009.65 100.48 n -Hexane 110543 0.0585 lb/bbl ProMax 44273.18 2213.66 2,2,4-540841 Trimethylpentane 0.0004 lb/bbl ProMax 293.81 14.69 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. COLORADO Form APCC-L05 - Condensate Storage Tank(s) APEN Revisioli 02/2017 5 Permit Number: AIRS ID Number: / / [Leave .ILan-; unless A,PCD�l?_ �c.�� -c AIRS lEn, 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. g\44761(AA lure of Legally Authorized Si Person (not a vendor or consultant) Jack Starr ate 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 For more information or assistance call: registration fee of $250, if applicable, to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-205 - Condensate Storage 7Gnkti≤1 A:PLtd - Revision 02/2017 6 I ®' COLORADO Hello