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Home My WebLink About20180203.tiff'COLORADO Department of Public ! Health El Environment RECEIVED JAN 0 4 2018 WELD COUNTY COMMISSIONERS 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 January 2, 2018 Dear Sir or Madam: On January 4, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Dunn 7 Sec HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health & Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Clara Gonzales Regards, Clara Gonzales Public Notice Coordinator Stationary Sources Program Air Pollution Control Division Enclosure 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer f?velac v;ew crc PLCi U'lITP),f-ILCJT), PcvCER/CH/\TM/C lc) Olt l'7/ opts/18' 2018-0203 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Dunn 7 Sec HZ - Weld County Notice Period Begins: January 4, 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: Dunn 7 Sec HZ Oil and gas production facility SWSW Sec 7 T5N R64W Weld County The proposed project or activity is as follows: Applicant proposes to increase production at an existing well production facility based on the addition of eleven (11) newly drilled wells. 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 17WE0970 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: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us A. Ad Colorado Air Permitting Project PRELIMINARY ANALYSIS - PROJECT SUMMARY Project Details Review Engineer: Bradley Eades Package N: 369038 Received Date: 9/1/2017 Review Start Date: 12/6/2017 Section 01- Facility Information Company Name: PD€€Energy, -Inc. County AIRS ID: 123 Plant AIRS ID: 1446 Facility Name: Dunn 7 Sec HZ Physical Address/Locatio SWSW quadrant of Section 7, Township 5N, Range 64WW, in Weld County, Colorado Type of Facility: Exploration & Production Well Pad What industry segment? Oil &.9iatural Gas Production & Processing, Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? Don Monoxide (CO) Pa icula[e Matter (PM) ®ne (NOx & VOC) Weld Quadrant Section Township Range 64W SWSW 7 5N Section 02 - Emissions Units In Permk Application AIRs Point 9 Emissions Source Type Equipment Name Emissions Control? Permit M Issuance 9 Self Cert Required? Action Engineering Remarks 001 Condensate Tank Yes 17W E0970 1 Yes Permit Initial Issuance Previously GP01 - New wells Section 03 - Description of Project PDC is adding eleven (11) newly -drilled wells to an existing well production facility.. In addition to the new wells, the source is adding min e (9) new natural gas fired engines to be registered under GP02, a hydrocarbon liquid loaodut point, and a new GPOS for produced water tanks. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting Synthetic Min real Section 05 - Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No, If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Yes 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) No yes 502 NOx CO VOC PM2.5 PM10 TSP HAPs Is this stationary source a major source? No If yes, explain what programs and which pollutants hers SO2 NOx CO Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) . VOC PM2.5 PM10 TSP HAPs ❑ ❑ Condensate Storage Tank(s) Emissions Inventory Section 01 - Administrative Information 'Facility AIRs ID: 123 1446 001. County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Two 2) condensate storage tanks consisting of Twenty-two (22) liquid manifold storage vessels and two (2) liquid'. Description: manifold storage vessels respectively. 22 liquid manifold vessel tank is herein referenced as TK-1 Ill 2 liquid manifold vessel tank is herein referenced as TK-1 (2) Emission Control Device Enclosed combustor Description: Requested Overall VOC & HAP Control Efficiency 85: 95 Section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput =- Potential to Emit (PTE) Condensate Throughput TK-1)1) = Potential to Emit (PTE) Condensate Throughput TK-1(2)= 1,523,546 Barrels (bbl) per year 1,523,546. Barrels (hbl) per year 1,827,247 Barrels (bbl) per year 1,008': Barrels (bbl) per year Secondary Emissions - Combustion Device(s) Heat content of waste gas = 2457.01 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 19.26849494 scf/bbl Actual heat content of waste gas routed to combustion device = Requested heat content of waste gas routed to combustion device = Actual Condensate Throughput While Emissions Controls Operating = 1,523546 Barrels (bbl( per year 72,129 MMBTU per year 72,129 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 86,5555 MMBTU per year Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Emission Factors Condensate Tank Pollutant Uncontrolled Controlled (lb/bbl) (lb/bbl) (Condensate Throughput) (Condensate Throughput) Emission Factor Source VOC Benzene Toluene 1.6122 0.0041 0.0056 0.0002... 0.0025.. 5:0312 0.0002::: 0.0806 0.0002 0.0003 1.05E-05 0.0001 0.0016 1.06E-05 Ethylbenzene Xylene n -Hexane 224 TMP Emission Factor Source Pollutant Control Device Uncontrolled Uncontrolled (Ib/MMBtu) (lb/bbl) (waste heat combusted) (Condensate Throughput) PM10 PM2.5 NOx CO 0.0075 0.0075 0.1380 0,2755:' '. 0.0004 0.0004 0.0065 0.0130 Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year( (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 1473.8 1228.1 61.4 1228.13 61.41 0.3 0.3 0.3 0.27 0.27 0.3 0.3 0.3 0.27 0.27 6.0 5.0 5.0 4.98 4.98 11.9 9.9 9.9 9.94 9.94 Hazardous Air Pollutants Potential to Emit Uncontrolled (lbs/year) Actual Emissions Uncontrolled Controlled (lbs/year) (lbs/year) Requested Permit Limits Uncontrolled Controlled (lbs/year) (lbs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 7457.8 6215 311 6215 311 10177.4 8481 424 8481 424 385.4 321 16 321 16 4561.4 3801 190 3801 190 56970.5 47475 2374 47475 2374 389.3 324 16 324 16 Section 06 - Reeulatory Summary Analysis Regulation 3, Parts A, B Regulation 7, Section %II.C, D, E, F Regulation 7, Section %II.G, C Regulation 7, Section XVII.B, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart 0000 Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet for detailed analysis) Source requires a permit Storage tank is subject to Regulation 7, Section XII.C-F Storage Tank is not subject to Regulation 7, Section %II.5 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3 Storage tank is subject to Regulation 7, Section XVII.C.2 Storage Tank is not subject to NSPS Kb Storage Tank is not subject to 5505 0000 Storage Tank is not subject to MACT HH 2 of 3 K:\PA\2017\17WE0970.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Section 07 - Initial and Penodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance ' testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? Ifyes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being permitted? This sample should be considered representative which generally means site -specific and collected within one year of the application received date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it may be appropriate to use an older site -specific sample. If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08- Technical Analysis Notes This paint was previously registered under GP01 however this modification is to permit the addition of a new storage tank consisting of 221 iquid manifold vessels. Thes new storage tank receives ondensate from 11 newly drilled welts.'. Theexisting: storage tank consisting of 2 liquid manifold vessels receives condensatefrom the 2 existing wells at the facility. Per applicant request, these respective sets of tanks are being grouped as a single emission point and permitted with combined limits Sinceeach set of storage tanks has a distinguishable throughput, each set of storage tanks were evaluated separately for determination of NSPS 0000 or. 0OOOa appfcability: PDC indicated the following potential throughputs for the respective storage tanks: TK-01(1)'= 1522706 bbl s 1.2= 1,827,247 bbl'. TK 01(2}-=840 bbl x1.2.=1,008 bbl Multiplying each by the controlled VOC emissmn factor:: TK O1(1)= 73.6 tpy VOC. TK-01(4}= 0.04 toy VOC Dividing by the respective number of liquid manifold vessels in eachstorage tank:. TK-01(1) = 3.4 toy Per -vane, TK 01{21.=0.02 tpy per vessel As such,the enforceable. PTE (since controls aye required per Regulation 7 Section (NM of each set of stoage tanks is below the 6 tpy threshold contained in NSPS 0000 and NSPS 0000a as referenced in the regulatory analysis sheet. Upon review of the draft permit, applicant requested that requirement to submit notice of startup (NO51 be removed since NOS was submitted with anginal application. Souce provided a: copy with date stamp of the NOS indicating that the operetta. assigned to 17WE0970began on June 03, 2017. NOS was received electronically on 12/28/2017. Therefore, I removed the requirement to submit NOS. Section 09 - Inventory SCC Coding and Emissions Factors AIRS Point a 001 Process 0 SCC Code 01 4 Uncontro Iled Emissions Pollutant Factor Control % Units PM10 0.01 0 lb/1,000 gallons condensate throe PM2.5 0.01 0 lb/1,000 gallons condensate throw NOx 0.16 0 lb/1,000 gallons condensate throu VOC 38.4 95 lb/1,000 gallons condensate throu CO 0.31 0 lb/1,000 gallons condensate throw Benzene 0.10 95 lb/1,000 gallons condensate throw Toluene 0.13 95 Ib/1,000 gallons condensate throw Ethylbenzene 0.01 95 lb/1,000 gallons condensate throu Xylene 0.06 95 lb/1,000 gallons condensate throu n -Hexane 0.74 95 lb/1,000 gallons condensate throu 224 TMP 0.01 95 lb/1,000 gallons condensate throu 3 of 3 K:\PA\2017\17WE0970.CP1.xlsm CONSTRUCTION PERMIT Permit number: Date issued: Issued to: 17WE0970 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: PDC Energy, Inc. Dunn 7 Sec HZ 123/1446/001 SWSW Sec 7, T5N, R64W Weld County Well Production Facility Equipment or activity subject to this permit: 1 Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 001 Twenty-two (22) 538 barrel fixed roof storage vessels used to store condensate Enclosed Flare Two (2) 300 barrel fixed roof storage vessels used to store condensate. 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 operator's responsibility to self -certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self -certify compliance as required by this permit may be obtained online at www.colorado.Qov/pacific/cdphe/air-permit-self- certification. (Regulation Number 3, Part B, Section III.G.2.) 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 COLORADO Air Pollution Control Division Page 1 of 8 line. (Regulation Number 3, Part B, Section 3. he o ato hall .mpg to all itial mpliance sting and sampling as required in this permit bmi th°°i as pare »₹ he self-certification.._process. (Regulation Number 3, Part B, Section III.E.) 4. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO, VOC CO TK-1 001 --- 5.0 61.5 10.0 Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per year. Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year. The facility -wide emissions limitation for hazardous air pollutants shall apply to all permitted emission units at this facility. Compliance with the annual limits, for both criteria and hazardous air pollutants, shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder shall calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled TK-1 001 Enclosed Flare 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 COLORADO Air Pollution Control Division Pn€ Page 2 of 8 ughput 1,523,546 barrels 11 m for nthly proc s rates based on the calendar month. pliant` th l throtrg' p its sha' .- 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 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 Lt MAINTENANCE REQUIREMENTS COLORADO Air Pollution Control Division Page 3 of 8 14. Ply" part B, Section COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements operate :e ing fo basis withy �proval pri shall follow the most recent operating and at approved by the Division, in order to e requirements of this permit. Revisions to to implementation. (Regulation Number 3, 15. 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 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 No. 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 (Reference: Regulation Number 3, Part D, V.A.7.B). GENERAL TERMS AND CONDITIONS COLORADO Air Pollution Control. Division 19. his p it ° . y atta hrrents m retai equest h- •e it may I4e3.. ued t a w own Jumbe, t B ' ecti . II.B upon ': equest for; eviAPE .nd reduired e. d and made available for inspection upon by the APCD as provided in AQCC Regulation ransfer of ownership and the submittal of a 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: Bradley Eades Permit Engineer COLORADO Air Pollution Control Division Page 5 of 8 ua a e Description suany; 1 Phis Is anc Issued PDC Energy, Inc. Permit rep aces GP01 and reflects the addition of 22 vessel storage tank COLORADO Air Pollution Control Division Page 6 of 8 Notes 1) ThN ermitold is .uire. . p.fees . tle proceing time for this permit. An invoice for these fewill bssuermit¢ issu . The per t holder shall pay the invoice within 30 days of invilur poathe inv ill result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. N per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (Ib/yr) 001 Benzene 71432 6215 311 Toluene 108883 8481 424 Ethylbenzene 100414 321 16 Xylenes 1330207 3801 190 n -Hexane 110543 47475 2374 2,2,4- Trimethylpentane 540841 324 16 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.0065 0.0065 TNRCC Flare Emission Guidance CO 0.0130 0.0130 V0C 1.6122 0.0806 ProMax 4.0 71432 Benzene 0.0041 0.0002 108883 Toluene 0.0056 0.0003 100414 Ethylbenzene 0.0002 1.05E-05 1330207 Xylene 0.0025 0.0001 110543 n -Hexane 0.0312 0.0016 540841 2'2'4 Trimethylpentane 0.0002 1.06E-05 COLORADO Air Pollution Control Division Page 7 of 8 te: Th oni lh missio _ fa;,ors for is int are " sed on, the flare control efficiency of 95%. 6) In a: cordar e w S. 25 ` ea Air Polluta Emission Notice (APEN) associated with thi ermi va fo ter of fi year ° rom the d. e it was received by the Division. A revised e tt er t befor .x 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: VQC, CO, NOx, n -Hexane, Total HAP NANSR Synthetic Minor Source of: VOC, NOx 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 Page 8 of 8 Condensate Storage Tank(s) APEN Form APCD-205 V1 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: /7tVEP97O AIRS ID Number: 123 / 1446 /001 [Leave blank unless APCD bay alreadh� sd peern-jt and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Dunn 7 Sec HZ Site Location: SWSW Sec 7 T5N R64W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Phone Number: E -Mail Address2: Jack Starr (303) 860-5800 Jack.Starr cf:!Ddce.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. COLORADO Form - Condensate Storage Tank(s) , PEN erosi 02:2017 1 Permit Number: AIRS ID Number: 123 / 1446 / 001 [Leave blank unless APCD I1ns already ned a permit = and AIRS ID] Section 2 - Requested Action j NEW permit OR newly -reported emission source 0 Request coverage under traditional construction permit ❑ Request coverage under a General Permit ❑ GP01 ❑ GP08 If General Permit coverage is requested, the General Permit registration fee of $250 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change in equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership3 ❑ Other (describe below) -OR - ❑ APEN submittal for update only (Note blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - • APEN submittal for permit exempt/grandfathered source Additional Info a Notes: Eleven (11) new well additions aggregated to previously permitted facility; Additional equipment added to location; Request a change of permit coverage form 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: hours/day 5/8/1986 7 ❑✓ Exploration a Production (EEt)) site days/week 52 weeks/year ❑ 'tidstream or Downstream (non E&P) site Will this equipment be operated in any NAAQS nonattainment area? • Yes • No Are Flash Emissions anticipated from these storage tanks? p Yes • No Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? 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 Storane TenHs1 ,=.FEI/ Revision 02/2017 2 I AV COLORADO ❑c,nmem cr F.tak owaonmenr Permit Number: AIRS ID Number: 123 / 1446 / 001 Llan« unicss 4PCD h__ rea :s D. teen- - and LIPS ID1 Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (bbl/year) Condensate Throughput: 1,523,546 1,523,546 From what year is the actual annual amount? 2017 Average API gravity of sales oil: 49.1 degrees ❑ Internal floating roof Tank design: ✓❑ Fixed roof RVP of sales oil: 7.8 O 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 (1) 22 11836 12/2016 6/2017 TK-1 (2) 2 600 1/2001 5/1986 Wells Serviced by this Storage Tank or Tank Battery5 (EEtP Sites On y) API Number Name of Well Newly Reported Well 05 - 123- 42828 Dunn 71-201 0 05 - 123- 42833 Dunn 71-221 0 05 - 123- 42823 Dunn 71-321 IN 05 - 123- 42830 Dunn 7L-201 O 05 - 123- 42827 Dunn 7L-221 0 4 Requested values will become permit limitations. Requested limit(s) should consider future growth. 5 The E&P 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) 40.40863 / -104.598271 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 El Downward El Other (describe): Indicate the stack opening and size: (check one) ❑ Circular o Square/rectangle ❑ Other (describe): ❑ Upward with obstructing raincap Interior stack diameter (inches): Interior stack width (inches): Interior stack depth (inches): Form APCD -__ n _ _ Revision 07' 70-i. 3 I COLORADO ,- Iv-, Permit Number: AIRS ID Number: 123 / 1446 / 001 lac trHtrt, P_J Ilc aiCac'ysi2i ed a permit- and 11.I -(S D] l in 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. Vapor El Recovery Unit (VRU): Pollutants Controlled: Size: Make/Model: Requested Control Efficiency: % VRU Downtime or Bypassed (emissions vented): % ❑ Combustion Device: Pollutants Controlled: VOC, HAPs, BTEX Rating: MMBtu/hr 14 x Cimarron 48", 2 x Cimarron 60" Type: Enclosed Combustor Make/Model: Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: Btu/scf Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 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 (E&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the st: ge tank(s)? 34 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator Form 2,PCD-205 - CiDnderisante Revision 02/2017 4 I AV COLORADO H F,.1 n 1, ,,It�E�� iri�nni Permit Number: AIRS ID Number: 123 / 1446 / 001 [Leave blank unless ! PCD has l ear s a pasmit a an: ',tR'S ID1 Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form°. 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) y ) Controlled Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 1.6122 lb/bbl ProMax 1228.10 61.41 1228.10 61.41 NOx 0.1380 Ib/MMBtu TCEQ N/A 4.98 N/A 4.98 CO 0.2755 Ib/MMBtu TCEQ N/A 9.94 N/A 9.94 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 0.0041 lb/bbl ProMax 6214.85 310.74 Toluene 108883 0.0056 lb/bbl ProMax 8481.16 424.06 Ethylbenzene 100414 0.0002 lb/bbl ProMax 321.15 16.06 Xylene 1330207 0.0025 lb/bbl ProMax 3801.17 190.06 n -Hexane 110543 0.0312 lb/bbl ProMax 47475.40 2373.77 2,2,4- Trimethylpentane 540841 0.0002 lb/bbl ProMax 324.41 16.22 4 Requested values will bea , 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. -ohm APCD-205 - Condensate Stc - any!'.`- rhahsaslos, __, 20117 51 Air COLORADO H .. E.v,nnneni Permit Number: AIRS ID Number: 123 / 1446 / 001 [LC = Lda u-Ie:r PCD has already as igred a permitcll`_i AIRS [Di 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. Signiure of Legally Authorized Person (not a vendor or consultant) Sicl /- I; ate Jack Starr EHS Professional Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance 0 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 Small h iness Assistance Program Environment Air Pollution Control Division APCD-SS-B1 43OO Cherry Creek Drive South Or visit the APCD website at: Denver, CO 8O246 -153O Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 ;303) 692-3175 or (303) 692-3148 https: //www.colorado.gov/cdphe/apcd Form APCD-2O5 Condensate I ' R_I; Rev is o n 0112[2,17 ,17 6 I Aiklif COLORADO I Il. 5 Er... en^. enf E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml Company Name: PDC Energy, Inc. Source Name: TK-1 Emissions Source AIRS ID2: 123 / 1446 / 001 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 42825 Dunn 7L-301 // 05 - 123 - 42832 Dunn 7L-341 i1 05 - 123 - 42831 Dunn 7Q-221 I1 05 - 123 - 42826 Dunn 7Q-241 ►1 05 - 123 - 42829 Dunn 7Q-301 .1 05 - 123 - 42824 Dunn 7Q-341 /1 05 - 123 - 13053 Dunn 1 ❑ 05 - 123 - 20239 Dunn 23-7 ❑ 05 - 123 - 19046 Dunn 24-7 ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ 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