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Home My WebLink About20183137.tiffCOLORADO Department of Public Health Er 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: SEP 2 5 2018 \AID C0MMSSCNERL On September 20, 2018, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - J Klein 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 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 I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pob(Re-Viet-kJ-(T ),PcQCeR/CN/50)/cIc),HL(JT) IQ/ I/1i? 2018-3137 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - J Klein 7 Sec HZ - 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: J Klein 7 Sec HZ Well Production Facility SWSE SEC 7 T5N R64W 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 17WE1191 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 AVIV COLORADO 1 I iltiV Colorado Air Permitting Project PREi1MINARY AlVALY515-PROJECT SUMMARY Project Details Review Engineer: Tirnothy!:SF;a�p Pacl�ge#: 363535�� Received Date: 6/9/2oi7.� �� RBVIBW St3rt D3t2: Il/�7/207�� ' Section Ol-Facility Information COmpanyNamO: �PDEErtergy.'�� .. �� quadrant Section Township Range CoUntyAIRS ID: 1?3 �`Weld '.. NWSE 32�- .. 1N '-�67' Plant AIRS ID: 9F2F FacifityName: JacobucsF32�Pad3 �� Phy5iCal Address/Lotati0 NWSE quadrant of Sectlon 32,Townshfp iN,Range 67W,in Weld County,Colorado � Type of Facility: .. Expiorati�n&Fecductton Wzll Fad � � Whatindustrysegment?Oit&NatvralGasPraduction&Fro�ess�ng � ' Is this facility located in a NAAQS non-attainment area? � - Yes �� If yes,for what pollutant? [�a�o�Mo�owde�co� [�articulate Matter(PM) [+�zone(NOx&VOC) Section 02-Emissions Units In Permit Application Emissions Seif Cert Engineering AIRs Point# Emissions Source Type Equipment Name Permit# Issuance# Action Control? Required? Remarks _..-.. _.__.... . . ... . .-AETtYtltltt1�13� ' � OQl Gander�safie 7ank Yes 17we05S5 1 Ye� tssuance Section 03-Description of Project Section 04-Public Comment Requirements � Is Public Camment Required? '�� Yes '� Ifyes,why? Hflques'�ngSyntheticMiz�earParm�t - . ....... � SecFion OS-Ambient Air Impad Analysis Requirement Was a quantitative modeling analysls required? '�:[dis _ � � ' '�.. If yes,for what pollutants? If yes,attach a copy of Technical 5ervices Unit modeling results summary. SecEion 06-Facility-Wide Stationary Source Classification � Is this stationary source a true minor? � . - {db� '�.. Is this stationary source a synthetic minor? ves ' If yes,indicate programs and which pollutants: so2 Nox co voc PM2.5 PMlo TSP HAPs Prevention of Signifcant Deterioration(PSD) � ❑ Q �Q � � Title V Operating Permits(OP) ❑ [� [] Q [� [] ❑ Q Nan-Attainment New Source Review(NANSR) �! ❑ Is this stationary source a major source? � �� If yes,explain what programs and which pollutants here so2 Nox co VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) �] Q � Q ❑ Q Title V Operating Permits(OP) � � ❑ � ❑ Q ❑ � Pkon-Attainment New Source Review(NANSR) Q �❑� � Condensate Storage Tank(s)Emissions Inventory Sec[ion 03-Adminis[rative Information = 1a3 .: , ..,9F73, � `" Q� -� .,,, ,,.,,, FacilityAlRsID: � County Plant Point Section 02-Eauipment Descriotion Details DetailedEmissonsUnit 16%XElOtShE�8568LbIYDta1j63t₹ery. "�'��, ;'-- �� , : ' '.: �3�17 Descnpt�an: ' , ,�'' , .:..' '.' '. . � � . Emis9on Conirol Dev re _p.17c�Aggt�E6ttthe�[4on devfce � "' ' "' �• " DescnPtlon: p '. ,��. ,,,-�� .,: � :.f �: ...: ... - ..�._,... . ...—, ,,,.,,, -- „ : : Requested Overall VOC&HAP Control Effciency%: 95 . Section 03-Processine Rate Information for Emissions Estimates Primary Emissions-Storage Tank(s) Actuai Condensate Thraughput= I��;�3L�,066'Barrels(bbl)per year Actual Condensate Throughput While Em ssons Conirols Operating= ��,4,130,Li6Q:'��,Barrels(b61)per year RequestedPermitLimitThroughput= I;13Q,663��.6arrels(66I)peryear �� Poterttial to Emit(PTE)Condensate Throughp it = 1;355,P72'�.flarrels(661)per year Secondary Emissions-Combustion Devi<e(s) . . Heatcontentofwastegas= '€';_,,,_1W4':8tu/scF � VolumeofwastegasemittedpereBLofliqu�ds � .::: ' produced= iscf/bbl Ac[u�heat con[ent of waste gas routed to com6ust on devi ce �� 53,519 MMBTU per year Requestedheatrontentofwastegasroutedtomm6ustiondevice= 63,519 MMBTUperyear Poterttial to Emit(PTE)heat content of waste gas routed to combustion device= 76,223 MMBTU peryear Sec[ion 04-Emissions Factors&Methadaloeies .��'`�''a. G. ,, Willthisstoragetankemitflashemissions� 'Yes �- EmissonFactors CondensateTank Uncontrolled Cantralled � Pollutant (16/661) (Ib/bbl) EmissionFactor5ource (Condensate (Condensate Throughput) Throughput) VOC 1.91 ��. 0.10 f'��j� � 8enzene O.OQS 0.000 - �� :�-�� F ud"e�₹��tj` ro�uene o.0�7: o.oao "5pesrs'�F��nudz�t�- ��/"�� Ethyldenzene Q,�Oa- O.OW � � �✓ %ylene 0.003�. 0.000 �� :/�,��`� '._ . n-Hexane �Q.646. 0.002 ��i,L�r�^.�a+kdesi(ashj� :". 224TMP fl.00Q; O.OOD � :S'��E.��"metudes �S��.__...,�,y �..-..: Control Device Umm�trolled Uncontrolled � Pollutant (16/MMetu) (Ib/661) EmissionFactor5ource (waste heat (Condensate com6us[ed) Thraughput) PM30 ' " ' O.OD00 : - ��'/�,.� � PM2.5 0.0000 �/� v�s -�� `�f� //��'�; _ Nox o,13sa� a0000 T�� u�z. �' :. ,� ,,,, ,.d, r�'�.�„ - co 0.27ss ..._.. o.0000 �3��. �[s_CYs�kfascce CFJ .._<....; ,-< Sec[ion OS-Emissions Inventory Potential to Emit Actual Emissions Requested Permit limits � Criteria Pollutants Unrontrolled Uncontrol�ed Controlled Uncontrolled Control4ed (cons/year) (tons/year� (tons/�ear) (tons/year� (tons/year� voc usza ios�.s sa.i iosl.s sa.i PM10 0.0 0.0 0.0 0.0 0.0 PM2.5 0.0 0.0 0.0 o.a 0.a NOx 5.3 4.4 4.4 A.4 3.4 CO 10.5 8.7 8.7 8.7 5.7 Potential m Emit Actual Emissions Requested Permit Limits HazardousAirPollutants Unrontrolled Uncontrolled Controlled Unconirolled Controlked (Ibs/year) �1bs/year) �Ibs/year) (Ibs/year) (16s/year) Benzene 6645 5537 277 5537 277 Toluene 9221 7684 384 7684 384 Ethylbenzene 407 339 17 339 17 Xylene 4068 3390 170 3390 170 n-Hexane 54785 45654 2283 45654 2283 224 TMP 271 226 11 22G 11 Sec[ion 06-Re¢ulatory Summary AnaHsis Regulation 3,Paris A,B Source requires a permit Regulation 7,Section XII.C,D,E,F Storage tank is subject�to Regulation 7,Section XII.C-F Regukatio�7,Section XII.G,C StorageTa�c is not su6jecito Regulation 7,Section XIi.G Regul:ation 7,5ection XViI.B,C1,C.3 Storagetank issubjectto Regulation 7,Section XV11,6,G1&C3 Regul.ation7,Sec[ion%VII.C2 ' Scora�etankissubject[oRegulaYion7,5ectionXViI.G2 Regu4ation 6,PartA,NSASSu6part K6 StarageTar�k is not subjectto NSPS Kb Regulation6,PartA,NB55ubpart0000 StorageTanlcisnotsu6jecctoN5P50000 Regul.ationB,PartE,MAQSubpartHH StoageTarkisnotsunjecLtoMACTHH . (See regulatory applicahility worksheet for de[ailed anatysis� � 3 of 4 � C:\Users\tsharp\Desktop\PA_17W E1191.CPl.xlsm Condensate Storage Tank(s)Emissions Inventory Section 07-Initial and Periodic Samoline and 7es[ine Reouirements ��Y-:..-,. . Does ihe com the state default emissions factors to estimate em ss�ons? �Wh��4 pany us if yes, re the umm�trolled actual or requested emiss ons estimated to he greater than or equal to S0 tons VOC per year? :Y.es;: Ifyes,the perm t will contain an Inrtial Compl�ance'test ng requirementto develop a srte specifc emissionsfactor based on guidelines in PS Memo OS Ol.� �� Does the mmpany use a srte spenfic emissons factor to est mate em ss�ons? ,g� ,� ._ �� e.:�� If yes and i there are flash emiss ons,are the emiss'ons factors 6ased on a pressuraed I quid sample drawn ai the ' �7`'f��"�� `�� _ fa<I ry be ng perm tted"+Th�s sample should be considered representat ve whi<h generally means site spenfic and +` �.� �,��(.� - coliected w th n one year of the appl canon received date However,f the fac I ty has not 6een modif ed(e.g.,no ,,;x ,��, y�^y wells 6rought on hne),then t may 6e appropnate to use an older s te-spec fic sampie �`��:1"f"' _ Ifeno,the permit will contain an"Initial Compliance"testing requiremen[to develop a site specifc emissions tactor based on guidelines in PS Memo OS-Ol. Does the company request a mntrol device eHiciency greater than 95%for a flare or com6ustion devire? If yes,the permii will contain and initial compliance test condition to demonstrate ihe destruction efficiencyof the comhustion device hased on inlet and outiet concentration sampling Section OS-Technical Anal sis Notes Section 09-Inventory SCC Codin¢and Emissions Factors Uncontrolled Emissions AIRSPoint# Process# SCCCode Pollutant Factor Control% Units 001 �l ��`� � � � �kfikar firealhh" Slss3sm tasses � PMSO 0.00 0 Ib/1,�00 Ilonsrondensatethrou h t �..��'�".� ....�'.��.. ;t� .,�. .__,...,'�°, �.. � . ,.,,.,,�,;i.�Y/�//�� ga g P� PM2.5 0.00 0 Ib/1,OOOgallonscondensatethroughput NOx 0.18 0 Ib/1,OOOgallonsmndensatethroughput � VOC 45.6 95 Ib/1,OOOgallons<ondensatethroughput � CO 0.37 0 Ib/1,OOOgallonsmndensatethroughput Benzene 0.12 95 Ib/1,OOOgallonsmndensatethroughput Toluene 0.16 95 Ib/1,OOOgallonsmndensatethroughput ' Ethyl6enzene 0.01 95 Ib/1,OOOgallons<ondensateihroughput � Xylene 0.07 95 Ib/1,OOOgallonscondensatethroughput n-Hexane 0.96 95 Ib/1,OOOgallonscondensatethroughput 224TMP 0.00 95 Ib/1,OOOgallonscondensatethroughput 4 of 4 C:\Users\tsharp\�esktop\PA_17W E1191.CPl.xlsm COLORADO Air Pollution Control Division Department of Public Health b Environment CONSTRUCTION PERMIT Permit number: Date issued: DRAFT Issued to: 17WE1191 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. J Klein 7 Sec HZ 123/9F73 SWSE SEC 7 T5N R64W 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 Sixteen (16) 538 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.) F.4. ) 4. The operator shall complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self -certification process. (Regulation Number 3, Part B, Section III.E.) 5. The operator shall retain the permit final authorization letter issued by the Division, after completion of self -certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 6. Emissions of air pollutants shall not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO. VOC CO Condensate Tanks 001 --- 4.4 54.1 8.8 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 1,130,060 barrels COLORADO Aix 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 ((KM) 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 O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen -minute period during normal operation. (Regulation Number 7, 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 NOX per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 19. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. COLORADO Aix 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 Controt 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/aqcc-regs 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emissions (lb/yr) Controlled Emissions (lb/yr) 001 Benzene 71432 5523 276 Toluene 108883 7698 385 Ethylbenzene 100414 284 14 Xylenes 1330207 3334 167 n -Hexane 110543 45637 2282 2,2,4- Trimethylpentane 540841 201 10 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x 0.1380 lb/MMBtu TCEQ CO 0.2755 lb/MMBtu TCEQ V0C 1.9141 Source ProMax 71432 Benzene 0.0049 Source ProMax 108883 Toluene 0.0068 Source ProMax 100414 Ethylbenzene 0.0003 Source ProMax 1330207 Xylene 0.0030 Source ProMax 110543 n -Hexane 0.0404 Source ProMax COLORADO Air Pollution Control Division Page 6 of 7 CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source 540841 2,2,4 Trimethylpentane 0.0002 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 COLORADO -'. Air Pollution. Control Division Page 7 of 7 Condensate Storage/'. (s) APEN Form APCD-205 Air Pollutant Emission Notice (APEN) an Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including P,EN updates. An application with missing information may be determined incomplete and may be returned or r ult in longer application processing times. You maybe 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: f'1 wE ( 19 1 AIRS ID Number: (Z3 /9F73/GOf [Leave blank unless APCD has already assiened a permit a and /,IR: ID] Section 1 - Administrative Information Company Name: Site Name: PDC Energy, Inc. J Klein 7 Sec HZ Site Location: SWSE 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: Jack Starr Phone Number: (303) 860-5800 E -Mail Address2: Jack.Starr@pdce.com 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 Tanks) APEN Revision 02/2017 COLORADO 1 hli b Enwo�uneN Permit Number: AIRS ID Number: / / k untess APCD -,_ ed ._ permit - re -'.IRS ID] Section 2 - Requested Action Q NEW permit OR newly -reported emission source ❑✓ Request coverage under traditional construction permit E Request coverage under a General Permit E 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 E 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 It 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 8/19/2017 7 ❑✓ Exploration a Production (EEEP) site days/week 52 weeks/year ❑ Midstream or Downstream (non EaP) site Will this equipment be operated in any NAAQS nonattainment area? Yes No p ■ Are Flash Emissions anticipated from these storage tanks? Yes No p ■ Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day? Yes No p ■ 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 O ■ Fo'-e APCD-205 Condensate .,tctta2e -art. APEN Revision 02/2017 COLORADO Health b cn.,.ununsn, Permit Number: AIRS ID Number: [Leave blank unless APCD has already assi_ned a permit = and AIRS ID] Section 4 - Storage Tank(s) Information Actual Annual Amount (bbl/year) Requested Annual Permit Limit4 (blot/year) Condensate Throughput: 1,130,060 1,130,060 From what year is the actual annual amount? 2017 Average API gravity of sales oil: 48.6 degrees ❑ Internal floating roof Tank design: E Fixed roof RVP of sales oil: 7.5 ❑ 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 16 8608 1/2017 8/2017 Wells Serviced by this Storage Tank or Tank Battery5 (EftP Sites Ony) API Number Name of Well Newly Reported Well 05 - 123- 43005 J Klein 7Q-321 0 05 - 123- 43000 J Klein 7T -121ST FA 05 - 123- 43001 J Klein 7T-201 ❑✓ 05 - 123- 43OO2 J Klein 7T-241 ❑✓ 05 - 123- 42999 J Klein 7T-301 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) 40.40787 / -104.59032 Operator Stack ID No. Discharge Height Above Ground Level (feet) Temp. (°F) Flow Rate (ACFM) Velocity (ft/sec) Indicate the direction of t'he stack outlet: (check one) O Upward ❑ Downward ❑ Horizontal ❑ 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 TanklsI APED - Rev pion 07,7017 3 COLORADO 1:17;:e. ePnmivu Permit Number: AIRS ID Number: [Leave Li.ank has f, ea c Dermit 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: Requested Control Efficiency: VRU Downtime or Bypassed (emissions vented): Make/Model: ❑ Combustion Device: Pollutants Controlled: VOC, HAPs, BTEX Rating: MMBtu/hr Type: Enclosed Combustor 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 ❑ No Pilot Burner Rating: 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 (EitP 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 For -m APCD-L05 Condensate Stora e unlasl APEN - Revi: onI A_VCOLORADO = b Ennronmeni Permit Number: AIRS ID Number: [Leave blank unless APCD has already ESsined a parr -Fit = dab 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 (or combined) control efficiency (% reduction): 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 Emissions (Tons/year) Uncontrolled Emissions (Tons/year) Controlled Emissions (Tons/year) VOC 1.9141 lb/bbl ProMax 1081.51 54.08 1081.51 54.08 NOx 0.1380 lb/MMBtu TCEQ N/A 4.38 N/A 4.38 CO 0.2755 Ib/MMBtu TCEQ N/A 8.75 N/A 8.75 Non -Criteria Reportable Pollutant Emissions Inventory Chemical Name Chemical Abstract Service (CAS) Number Emission Factor6 Actual Annual Emissions Uncontrolled Basis Units Source (AP -42, Mfg. etc) g Uncontrolled Emissions Pounds/ ear (Pounds/year) ) Controlled Emissions? (Pounds/year) Benzene 71432 0.0049 lb/bbl ProMax 5522.98 276.15 Toluene 108883 0.0068 lb/bbl ProMax 7698.12 384.91 Ethylbenzene 100414 0.0003 lb/bbl ProMax 284.47 14.22 Xylene 1330207 0.0030 lb/bbl ProMax 3333.96 166.70 n -Hexane 110543 0.0404 lb/bbl ProMax 45636.98 2281.85 2,2,4- Trimethylpentane 540841 0.0002 lb/bb ProMax 200.80 10.04 4 Requested values will become permit limitations. Requests I limit(s) should consider future growth. 6 Attach condensate liquid laboratory analysis, stack test re:.,lts, 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. Form APCD-=_= Condensate Storage Tank(s) APEN - Revision C_ 5 I AVCOLORADO '!„,=. Permit Number: AIRS ID Number: / / [Leanne h arl unless ;PCE has already assyned aP 2S 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. ature of Legally Authorized Person (not a vendor or consultant) Jack Starr EHS Professional Name (print) Title Check the appropriate box to request a copy of the: ❑ Draft permit prior to issuance Q 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 Business Assistance Program Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Or visit the APCD website at: Denver, CO 80246-1530 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 Coriiens_ t.c a0 si APEN Revisor 6 I .11.11 COLORADO Devvfinen, a/Public Ne„. Er Er,vanment Hello