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Address Info: 1150 O Street, P.O. Box 758, Greeley, CO 80632 | Phone:
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egesick@weld.gov
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20171248.tiff
COLORADO Department of Public Health Er Envirorunent 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 April 27, 2017 Dear Sir or Madam: RECEIVED MAY 01 2017 WELD COUNTY COMMISSIONERS On April 27, 2017, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Bihain 26F -232,332;26G-202,212,312. 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 I John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Pblic CC PLCmflmITP), CP6), Rvrew pr,0 c£R/C 11CK f J -m) siOiI -j 5/2./(1 2017-1248 Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Bihain 26F -232,332;26G-202,212,312 - Weld County Notice Period Begins: April 27, 2017 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: PDC Energy, Inc. Facility: Bihain 26F -232,332;26G-202,212,312 Well production facility SWNW Section 26 T5N R64W Weld County The proposed project or activity is as follows: Well production facility in non -attainment area; this construction permit includes condensate storage vessels and truck loadout. Other emission points at the site are four (4) engines covered by GP02 general permit. 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 Permits 17WE0089 and 17WE0090 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: Andy Gruel Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd®state.co.us 1 I AVCOLORADO mow. Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Andy. Gruel 357883 1/30/2017 4/12/2017 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Ctllfaturais Ffrodt Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? El Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application PDC Energy, Inc 123 9F09 Bihain 26F-232,332;266-202,212,312 SWNW quadrant of Section 26, Township 5N, Range 64W, in Weld County, Colorado Weld Quadrant Section Township Range 5N 64 ❑ Particulate Matter (PM) DI Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 003 Condensate Tank TK-1 Yes; ,,; 17W E008€ 1 Yes Permit Initial Issuance 004 Hydrocarbon liquid Loading LOAD -1 Yes j7WE009C 1 Yes : Permit Initial Issuance Section 03 - Description of Project New synthetic minor well production facility in the non -attainment area. Project also includes GP02 registrations for engines, at points 001, 002, 005, and 006. Loadout satisfies new RAcr requirements through direct control by enclosed combustor. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? Requesting, ii Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? Na If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Lr Pe Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Yes _ SO2 NOx CO VOC PM2.5 PM10 TSP HAPs O 0 0 ❑ 0 ❑ O 0000 000 0 o SO2 NOx CO VOC PM2.5 PM10 TSP HAPs O 0000 0 O 000 ❑ 000 ❑ ❑ Condensate Storage Tank(s) Emissions Inventory Section 01- Administrative Information 123 Facility AIRS ID: Plant Point Section 02- Equipment Description Details Detailed Emissions Unit Ten 100)1538 -bbl twee - Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency 06: Iphenic Condensate storage vessels. combustors (4 x Cimarron 48", 1x 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 = Secondary Emissions - Combustion Device(s) Heat content of waste gas = Volume of waste gas emitted per BBL of liquids produced = 29.945'. scl/bbl Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = 774,960 Barrels (bbl) per year 774,960 Barrels (bbl) per year 29'952 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 774,960 Barrels (bbl) per year !'. Btu/scf from ProMas model from ProMax model, includes flash and W/8 emissions, divided by model throughput (774968 bbl/yr) 61,732 MMBTU per year 61,732 MMBTU per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = 74,078 MMBTU per year The MMBtu/yr amounts I calculated using the ProMax outputs were less than those presented by applicant on the talc sheets. The amounts entered above (MMetu/yr) reflect the amounts calculated by the applicant, which are higher than what I calculated. Section 04- Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant IMMEME Uncontrolled Controlled (Ib/bbl) (Ib/bbl) (Condensate Throughput) Pollutant __.00056. _... _. 0.0019 ..........0.0504......1? (Condensate Throughput) 0.0003 0.0003 0.0000 0.0001 0.0025 0.0000 Control Device Uncontrolled Uncontrolled (lb/MMBtu) (waste heat combusted) (lb/bbl) (Condensate Throughput) 0.2755 Emission Factor Source Emission Factor Source Section 05 - Emissions Inventory Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) VOC PM10 PM2.5 NOx CO 1261.3 1051.1 52.55 1051.1 52.55 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 5.1 4.3 4.26 4.3 4.3 10.2 8.5 8.50 8.5 8.5 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Requested Permit Limits Uncontrolled Controlled (Ibs/year) (Ibs/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TRIP 2.6028 2.1690 0.1084 2.1690 0.1084 4338 217 2.8316 2.3597 0.1180 2.3597 0.1180 4719 236 0.0954 0.0795 0.0040 0.0795 0.0040 159 8 0.9001 0.7501 0.0375 0.7501 0.0375 150O 75 23.4551 19.5459 0.9773 19.5459 0.9773 39092 1955 0,1790 0.1492 0.0075 0.1492 0.0075 298 15 Section 06 - Regulatory Summary Analysis I Regulation 3, Parts A, B IPermit and APEN required 2 of 3 K:\PA\2017\17 W E0090.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Regulation 7, Section XII.C, D, E, F Regulation 7, Section XII.G, C Regulation 7, Section XVII.0, C.1, C.3 Regulation 7, Section XVII.C.2 Regulation 6, Part A, NSPS Subpart Kb Regulation 6, Part A, NSPS Subpart OOOO Regulation 8, Part E, MACT Subpart HH (See regulatory applicability worksheet for detailed analysis) Storage tank is subject to Regulation 7, Section XII.C-F, as provided Storage Tank is not subject to Regulation 7, Section XII.G Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a Storage tank is subject to Regulation 7, Section XVII.C.2, as provide Storage Tank is not subject to NSPS Kb Storage Tank is not subject to NSPS OOOO Storage Tank is not subject to MAR HH Section 07 - Initial and Periodic Sampling and Testing Requirements Does the company use the state default emissions factors to estimate emissions? If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash emissions, are the 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? ' a 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 NOS and CO emissionswere calculated using ProMasmodel output. I usedthe ProMaX output to calculate a total MM8tu/yrthroughputto the flare in order to apply the Nov and CO emission factors The MMBtu/yr amounts I calculated were a bit lower than thosepresentedhy the applicant. I choseto accept theamounts presented bythe applicant as conservative. The MM13tu/yramounta mitered in Section 03.abovereflectthe amounts calculated bythe applicant. VOCand HAP emissions were modeled using ProMasbased on a model throughput of 774,968 bbl/yr. The ProMaxmass flow modeled amounts (Ib/yr)Iwere divided; by the lb/bbl emission factors enteredabove, which match the APEN. section 09 - Inventory SCC Coding and Emissions Factors AIRS Point 8 003 Process e 01 SCC Code Uncontrolled Emissions Pollutant Factor Control % Units NOx 0.262 0 lb/1,000 gallons condensate throughput VOC 64.586 95 lb/1,000 gallons condensate throughput CO 0.523 0 lb/1,000 gallons condensate throughput Benzene 0.133 95 lb/1,000 gallons condensate throughput Toluene 0.145 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.005 95 lb/1,000 gallons condensate throughput Xylene 0.046 95 lb/1,000 gallons condensate throughput n -Hexane 1.201 95 lb/1,000 gallons condensate throughput 224 TMP 0.009 95 lb/1,000 gallons condensate throughput 3 of 3 K:\PA\2017\17WE0090.CP1.xlsm 79 E 2 E 2 0 O z T 0 U N re a N `m O w C REMARKS New Facility - No Previous Total new GP02 Jan 2017 GP02 cavcviie<1 March 201r - tepfaced by 006 SSEFs approved controlled by direct flare, granted 95% new GP02 Feb 2017 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hexane 8 Total HH: Minor 7777: Syn Minor 'Excludes units exempt from permits/APENs Pubcom required due to new syn minor limits Facility is eligible for GP02 because < 90 tpy Project emissions less than 25150 tpy This initial history file consolidates four separate CP/GP02 packages received in January, February, and March 2017. _ Ts a F= o0 00 o ") ON .-00 ' 0 000 600 1": — � .- O o 0o o0 r .- )0 M c6 6 U) r .- 0 r 0) r--. r... 0101 a)8 0 a > o 0 0 0 0 0 o o 00 O O 00 00 0 O <0 W to 0 0 O: O O O O M 0. O N V R )Oh N 10)00 X z 0 0 o d co O co NO V O W 0 O N .- W r rr cc. O Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) N O N O O O o o 0 O 0 o 0 rn N N = O o 0 0 a 0 0 0 00 co N 2 0. 0 0 6 0 0 0 0 o M 0 N N 0 0 O a 0 0 0 0 0 O 0 O M 0 N N 0 0 A a 7o. = 0 0 o O N,- N N ,- O O O O O O O O V t0 NN V' to N O o co 6 0 M 0) O M odd CD M 0) a a a O v a0 LL o 0 0O 0 0 0 o o 0 UO a 0 o 7 O) .71 Qig M f0 6o o 0 M 0 -4: c h o 0% 2 00 6o M N V O<O O p co, N N 0 0 O O a 0 0 0 N S O O o O o 0 O N 0 0 0 0 0 0 0 0 O M 0 N 0 O .- 0 0 0 O 0 0 0 0 0 co 0 N 0 Description 'Previou• s FACILITY TOTAL Previous Permitted Facility total GM Vortec 5.7L, sn: 10CH MM408070032 Si 2 S o =x 1 Condensate storage, 5380 bbl Hydrocarbon loadout Red River GM 9.0, sn: 306655 GM Vortec 5.7L, sn: 10CH MM405270007 External Combustion Sources Fugitives Produced Water Tanks 'Permitted Facility Total• (Al Change in Permitted Emissions FACILITY TOTAL GP02 0 0 0 o 33 r-- GP02 GP02 E' a c 0 PERMIT . ! z N O z o C aSo u) 6 o W Z d a F 2 chM aa2 z [rz] O z w n ° Z ▪ , • r t • Q • g • F O 0z Q = N O 0 w x r H • 'a o Q w 0 O O a O O U m d a w a C) O C O U C O M E w 'O et - O F- O .- O - 0 O 7 O N N .- 0 0 N O O N x O O 0 0- M I- n4'.1 0 CO 0 N N o McOH o 0 N F O CO N O p n -Hexane a 39092 1495 ~ N CO N Xylenes 0 1500 56 <O 25 m 0 2 gi N y L W 0 C) ..0 CO <O M G N F O N. v O r N m N N m a co) O T O M N o U Q O .- n CO N G O T 43 Q a O cs)N CD N O p - O C o) V N N O 'POINT PERMIT 'Description Previous FACILITY TOTAL GM Vortec 5.7L, sn: 10CHMM408070032 GM Vortec 5.7L, sn: 10CHMM404020057 Condensate storage, 5380 bbl Hydrocarbon loadout Red River GM 9.0, sn: 306655 GM Vortec 5.7L, sn: 10CHMM40527000- APEN-Exempt / Insignificants: External Combustion Sources Fugitives Produced Water Tanks GP02 cancelled W 0 CO CD 00 GP02 GP02 TOTAL (tpy) 0 N 0 M V' 0 O LO CO O 0 C E E a) a) A U1 O N E a) v U) o � � C 8a) g • V N N c 3o h w aE ¢a, x � Tr, u p C a o 0 oo_ a) X To H O a • N m i d a w O CC O ca L C O N N E w --- F O O O O O M. F O N e- O D co. F O O O N I O a O a N N o c McOH 0 0 N O M No q n -Hexane a d r n N O a1 ro g. O 75 3 O N O a) gi N W a O'- O CO o ci a) N F O co O) N <O N. O m c C m T N- N IT) O Q O m r-- co G O 43 T - Q 0 O N O o O v E La O M .- 0 M N cl O IPOINT IPERMIT IDescription Previous FACILITY TOTAL GM Vortec 5.7L, sn: 10CHMM408070032 GM Vortec 5.7L, sn: 110CHMM404020057 Condensate storage, 5380 bbl Hydrocarbon loadout Red River GM 9.0, sn: 306655 GM Vortec 5.7L, sn: 10CHMM40527000- APEN-Exempt / Insignificants: External Combustion Sources Fugitives Produced Water Tanks GP02 cancelled rn 0 co CO 0 0 O o N- N- GP02 GP02 TOTAytpy) 0 N 0 M V 0 0 u] <O 0 0 k C) w Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS non -attainment area? If yes, for what pollutant? ID Carbon Monoxide (CO) Andy Gruel 357883 1/30/2017 4/12/2017 PDC Energy, Inc. 123 9F09 Weld Quadrant Section Township Range 64 Bihain 26F -232332;26G-202,212,312 SWNW quadrant of Section 26, Township SN, Range 64W, in Weld County, Colorado E, rat£on & Pi Gtion Well P CI1i &Naturat l; ras Production' Section 02 - Emissions Units In Permit Application ❑ Particulate Matter (PM) 0 Ozone (NOx & VOC) AIRs Point # Emissions Source Type Equipment Name Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 003 - Condensate Tank' TK-1 e 17WE00& 1 Yes... rmit Initial •... is uance 004 Hydro carbon-trs wading LOAD-1 Yes , ' 17WE009C 1 Yes .. Pei lnitial.r ., ;,Issuance Section 03 - Description of Project New synthetic minor well production facility in the non -attainment area. Project also includes--GP02 registrations for engines, at points 001,002,, 005, and 006. Loadout satisfies new RACT requirements through direct control by enclosed combustor. Section 04 - Public Comment Requirements Is Public Comment Required? If yes, why? yet zynth Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required? If yes, for what pollutants? If yes, attach a copy of Technical Services Unit modeling results summary. Section 06 - Facility -Wide Stationary Source Classification Is this stationary source a true minor? Is this stationary source a synthetic minor? If yes, indicate programs and which pollutants: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) Is this stationary source a major source? If yes, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD) Title V Operating Permits (OP) Non -Attainment New Source Review (NANSR) es ... SO2 NOx ❑ ❑ ❑ El CO VOC El El ❑ 0 El PM2.5 PM10 TSP HAPs ❑ ❑ ❑ ❑ ❑ 0 502 NOx CO VOC PM2.5 PM10 TSP HAPs O 0 ❑ ❑ 0 0 ❑ ❑ ❑ ❑ ❑ ❑ ❑ 0 ❑ ❑ 004 Hydrocarbon Loadout to Tanker Trucks 123-9F09-004 17WE0090 CP1 Calculations L = (12.46*S*P*M/T)*C (AP -42: Chapter 5.2, Equation 1) L = loading losses in lb per 1000 gallons loaded Factor Meaning Value Units Source s Saturation Factor 0.6 AP -42 Table 5.2-1: Submerged loading P True Vapor Pressure 6.2563 psia M Molecular Weight of Var 52.434 ; lb/lb-mole Calculated based on equation 1 22 of AP 42 chapter 7.1 T Liquid Temperature 516.461 deg. R Field Data L Annual requested Throughput Annual requested VOC emissions Control: Direct Flare (colle Efficiency: NCRPs Component Mass Fraction 4.749 lb/10^3 gal 1.99E-01 lb/bbl n e7 95% Benzene 0.001721 Toluene 0.001856 Ethylbenzene 0.000062 0.00 Xylenes i78 n -Hexane 0.015494 2,2,4-TMP 0.000109 VOC Source: 36996O!BBL/yr 15538320 gal/yr 73785 lb/yr 36.89 tpy iciency assumed 100%, control efficiency 95%) 0.764509392 ProMax modeled HAP mass fractions in storage tank vapor. Emissions Summary Table Pollutant Emission Factor Uncontrolled Emissions Controlled Emissions Source NOx 0.1380 lb/MMBtu 0.15 tpy TNRCC CO 0.2755 lb/MMBtu 0.30 tpy TNRCC VOC 1.994E-01 lb/bbl 36.89 tpy 1.84 tpy AP -42 Benzene 4.488E-04 lb/bbl 166 lb/yr 8 lb/yr Mass Balance Toluene 4.843E-04 lb/bbl 179 lb/yr 9 lb/yr Mass Balance Ethylbenzene 1.608E-05 lb/bbl 6 lb/yr 0 lb/yr Mass Balance Xylene 1.508E-04 lb/bbl 56 lb/yr 3 lb/yr Mass Balance n -Hexane 4.042E-03 lb/bbl 1495 lb/yr 75 lb/yr Mass Balance 2,2,4-TMP 2.839E-05 lb/bbl 11 lb/yr 1 lb/yr Mass Balance I123 -9F09-004 17WE0090 CP1 Regulatory Review Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all subsections of Section II. A and B of this regulation. Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six minutes in any sixty consecutive minutes. Regulation 2 — Odor Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any single source such as to result in detectable odors which are measured in excess of the following limits: For areas used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous air has been diluted with seven (7) or more volumes of odor free air. Regulation 3 - APEN and Permitting Requirements Is this site considered an exploration and production location (e.g. well pad)? If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Does this operator unload less than 6,750 bbls per year of condensate via splash fill or 16,308 bbls per year of condensate via submerged fill procedure? No If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1 Yes No Part A-APEN Requirements Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual criteria pollutant (pollutants are not summed) for which the area is non -attainment. Applicant is required to file an APEN since emissions exceed 1 ton per year VOC. Part B — Construction Permit Exemptions Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a). Part B, III.D.2 - RACT requirements for new or modified minor sources This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or attainment/maintenance areas. This source is located in the 8 -hour ozone nonattainment area, but not the 1 -hour ozone area. The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the date of the 8 -hour ozone NA area designation). Since the tank battery from which loadout is occurring came into service after the date above (Reported as 07/02/14 on condensate tank APEN), this source is considered "new or modified." Operator is using submerged fill and direct vapor control by dedicated enclosed flare; RACT requirements are satisfied. Regulation 7 — Volatile Organic Compounds No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and distribution facility that has a daily average throughput of more than 76,000 liters of gasoline (20,000 gallons), which is loaded directly into transport vehicles. This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C. Regulation 8 — Hazardous Air Pollutants MACT EEEE: Not subject because facility is classified as a synthetic minor source of HAPs It should also be noted that the loadout operation is located at a production field facility and thus would be exempt per 40CFR 63.2334(c)(1). NCRP emissions were calculated by multiplying the VOC loading loss emission factor by the ProMax modeled mass fraction of the NCRP in the loaded vapors divided by the ProMax modeled mass fraction of VOC in the loaded vapors. The NOx and CO emissions associated with the loadout operation were determined using emission factors from TNRCC guidance document: the emission factors are 0.1380 lb/MMBtu and 0.2755 lb/MMBtu for NOx and CO respectively. Using these emission factors along with a gas flowrate (modeled by ProMax) of 2166.77 MMBtu/yr, emissions of NOx and CO were determined to be below APEN reporting thresholds, and so these limits are not contained in the permit. SCC CODING Pollutant Uncontrolled Emissions Factor (lb/1,000 gallons) Control Efficiency VOC Benzene Toluene n -hexane 4.7486 0.0107 0.0115 0.0962 lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons lb/1,000 gallons 95.0% 95.0% 95.0% 95.0% 40600132: Crude Oil: Submerged Loading (Normal Service) Use if S = 0.6 1123-9F09-004 17WE0090 CP1 N. 0 0 0 W C O 2 C C 0 C 0 W 0 a C 0 E C C O z N C C 0 O 0 C E z C a E 0 U a N K w U a N a co 4, a O N O C O U L U) z 0 y 2 W 0 m N a 0 O 4, d O C 0 u C N z 0 N W N < W W H y L o Z Z LL 0 Z new GP02 Jan 2017 N ISSEFsapproved controlled by direct flare, granted 95% new GP02 Feb 2017 VOC: Syn Minor (NANSR and OP) NOx: Minor (NANSR and OP) CO: Minor (PSD and OP) HAPS: Syn Minor n -hexane & Total HH: Minor 7777: Syn Minor Excludes units exempt from permits/APENs Pubcom required due to new syn minor limits Facility is eligible for GP02 because < 90 tpy Project emissions less than 25/50 tpy This initial history file consolidates four separate CP/GP02 packages received in January, February, and March 2017. a F = 00 06 7 0 0 O 700 N — 0 0 0 000 0 A 7 O 0 oo o O N 7 in mN 0do n. 7 o - . .. �.N- LL0 > 0 0 O O O 0 00 66 O0 > O t0 d 600 N CO d'0'Oh 6 O o O m N d. ,N Cdd. O Z 0 O O 0 O m N < 0 tO 0 0 O N 7 C! A N.N. 0{ p ' - Total VOC Facility Emissions (point and fugitive) (A) Change in Total Permitted VOC emissions (point and fugitive) N O CO O 0 O O 0 0 00 66 N N 0 0 00 O a o o 0 0 N a O 0 Co O O O O N 0 NN 60 a _ i a O a O O O O O 0 M O NN 60 m a E:1 o0 0 0 o 7 O 0.=0 N N 0 000 000 V CO N e+ 0 N O 0 oo 0 O M O) .00 66 m 7 O) 0 7 o n1 0 V 0O > 00 O O O a 0 O 0 0 o0 0O o 0 .-00 ,n mm o 0 o o 0 m O v m 0 N. 0 Z oo 00 a0 - mNO vd7 N 7 N - m a v N O N 00 O O c 0 0 Cl) N = 0 0 O O o 0 a O Cl) 0 a 0 0O a a O O M O N O a 2 a 0 0 O O O a a 0 C N O Description Previous FACILITY TOTAL Previous Permitted Facility total GM Vortec 5.7L, sn: 10CH MM408070032 GM Vortec 6.7L, sir I oCHMA4 040200.57 Condensate storage, 5380 bbl Hydrocarbon loadout Red River GM 9.0. sn: 306655 GM Vortec S.7L, sn: 10CH MM405270007 IAPEN-Exempt / Insignificants: 'External Combustion Sources Fugitives IProduced Water Tanks 'P ermitted Facility Total (A) Change in Permitted Emissions PERMIT GP02 ii y ai I17WE0089 17WED090 GP02 GP02 FACILITY TOTAL Z K a¢° o 5,, 0 m a.1 0 0 <0 0 o m t Z N C Z Printed 4/13/2017 s N 71- f.,7 O • Q Q 4.1 X ; � � 0. • j VI -7 Q 07 W Z -F7 0. a. O 0 PG O F.,' FO O H T O O O O N N 3 0 0 N O 0 a co I O O a a l- y N N O 03 0) N C‘I a McOH o 20 p M N o p n -Hexane O 39092 1495 N M N Xylenes O 1500 56 0 tO N m p m c m m L W o o 0 CO c0 r) d o N _ o C) 0 a r O r ul N C NO y CO .- CO') O M O a O .- .- O n M N N 2 Q O .- N .- 0 i. `w u o OD 0) 0) N a )L 0 M '- cn O M N .- N D IPOINT IPERMIT IDescription Previous FACILITY TOTAL � I GM Vortec 5.7L, sn: 10CHMM408070032 GM Vortec 5.7L, sn: 10CHMM404020057 Condensate storage, 5380 bbl Hydrocarbon loadout Red River GM 9.0, sn: 306655 GM Vortec 5.7L, sn: 10CHMM40527000- APEN-Exempt / Insignificants: External Combustion Sources Fugitives Produced Water Tanks GP02 cancelled O 0 CO O 33 GP02 GP02 TOTAL (tpy) 0 N 0 M R 0 0 0 0 0 0 N E E A N C O y N E m a U) O E o E 'a' y V N N C 3 Co h a_ - O N C o N c r 0 0 C) .. m x O a F N r O H O O - O O O C. O .- 0 N, 0 0 W O O a co N I O O a a I H ..fl O Lo O a McOH O O N O M N o p n -Hexane O 1955 75 03 N O Xylenes O N M )C N O EthylbenzeneI O co .- c0 co o a N N H- O M 0 N c0 O C) N N C 0 O .n- CO N '- <17)N G d 2 Q O• m N. m N 4 o T _ Q O 0) 0) 0) N G Q. E 0 M . - O M N .- N 0 'POINT'PERMITIDescription Previous FACILITY TOTAL GM Vortec 5.7L, sn: 10CHMM408070032 GM Vortec 5.7L, sn: 10CHMM404020057 Condensate storage, 5380 bbl Hydrocarbon loadout Red River GM 9.0, sn: 306655 GM Vortec 5.7L, sn: 10CHMM40527000- N C External Combustion Sources Fugitives Produced Water Tanks GP02 cancelled 0) O CO 0) O O w w �� GP02 GP02 U C C) w C n E w TOTAL (tpy) 0 N 0 M <- 0 0 K) co 0 0 Z W d Q 1239F09.xlsx Permit number: Date issued: Issued to: DO trol Division Department of Public Health e Environment CONSTRUCTION PERMIT 17WE0089 Facility Name: Plant AIRS ID: - Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Bihain 26F -232,332;26G-202,212,312 123/9F09 SWNW Section 26 T5N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description TK-1 003 Ten (10) 538 -barrel fixed roof storage vessels used to store condensate. Enclosed Combustor 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.gov/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 date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) COLORADO Air Pollution Control Division r F`.i^tu ri�taicr � ::n:^r<;s,rrr nc Page 1 of 7 3. '° o. a s ll pl e all i ial compliance testing and sampling as required in this ermi " d r'. it ' - - ults he Division as part of the 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-1 003 --- 4.3 52.6 8.5 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-1 003 Enclosed Combustors (4 x Cimarron 48", 1 x Cimarron 60") VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 003 Condensate throughput 774,960 barrels The owner or operator shall monitor monthly process rates based on the calendar month. COLORADO Air Pollution Control Division D,.ep.V.men cf Pubk: F"i:r tl ti `r, Envi= omro.,, - Page 2 of 7 l throu `' put limits shall be determined on a rolling twelve (12) al. he - '• "each •'`th 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 Et MAINTENANCE REQUIREMENTS 14. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OEtM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to COLORADO Air Pollution Control Division Depaftmont of Rtetlo Heath s Efhetchatetra Page 3 of 7 approval prior to implementation. (Regulation Number 3, COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 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 (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 18. 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. 19. 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 COLORADO Air Pollution Control Division r�sr,t rh Page 4 of 7 Details r obtaining final authorization to operate are located in rtify mat Authorization section of this permit. 20. 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. 21. 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. 22. 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 shalt 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. 23. 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. 24. 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: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. !COLORADO Sir Pollution Control Division :Fc C PU": of F) J' { f a'h Y '-3 s nrn^rnt Page 5 of 7 No th this it 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. Facility Equipment ID AIRS Point Pollutant CAS # Uncontrolled Emissions (tPY) Controlled Emissions (tPY) TK-1 003 Benzene 71432 2.17 0.11 Toluene 108883 2.36 0.12 Ethylbenzene 100414 0.08 0.004 Xylenes 1330207 0.75 0.04 n -Hexane 110543 19.55 0.9773 2,2,4 Trimethylpentane 540841 0.15 0.008 Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 0.125 tons per year (tpy) 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 003: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x --- 0.0094 TNRCC Flare Emissions Guidance CO --- 0.0188 V0C 2.7126 0.1356 ProMax model based on site specific pressurized liquid sample 71432 Benzene 0.0056 0.0003 108883 Toluene 0.0061 0.0003 100414 Ethylbenzene 0.0002 0.00001 1330207 Xylene 0.0019 0.0001 110543 n -Hexane 0.0504 0.0025 COLORADO Air Pollution Control Division Page 6 of 7 controlled mi ion Factors lb/bbl Controlled Emission Factors lb/bbl Source •o luta 540841 2,2,4-TMP 0.0004 0.00002 Note: The controlled emissions factors for this point are based on the flare control efficiency of 95%. N0x and CO emission factors are based on a fuel throughput of 61,732 MMBtu/yr. 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 (n -hexane and total) NANSR Synthetic Minor Source of: VOC MACT HH 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 Permit number: Date issued: Issued to: trot Division Department of Public Health b Environment CONSTRUCTION PERMIT 17WE0090 Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Bihain 26F -232,332;26G-202,212,312 123/9 F09 SWNW Section 26 T5N R64W Weld County Well Production Facility Equipment or activity subject to this permit: Facility Equipment ID AIRS Point Equipment Description Emissions Control Description LOAD -1 004 Truck loadout of condensate. Dedicated 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. This construction permit represents final permit approval and authority to operate this emissions source. Therefore, it is not necessary to self -certify. (Regulation Number 3, Part B, Section III.G.5.) EMISSION LIMITATIONS AND RECORDS 2. Emissions of air pollutants shall not exceed the following limitations (as calculated in the Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4) Annual Limits: Facility Equipment ID AIRS Point Tons per Year Emission Type PM2.5 NO), VOC CO LOAD -1 004 --- --- 1.9 --- Point Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. (COLORADO Air Pollution Control Division "h partmonf of F "off:: fl fi;'h _n II-Mfororonf Page 1 of 7 dual hazardous air pollutant shall not exceed 8.0 tons per 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. 3. The emission points in the table below shall be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility Equipment ID AIRS Point Control Device Pollutants Controlled LOAD -1 004 Dedicated Enclosed Flare controls emissions from loadout VOC and HAP PROCESS LIMITATIONS AND RECORDS 4. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rate shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Reference: Regulation 3, Part B, II.A.4) Process/Consumption Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit LOAD -1 003 Condensate Loaded 369,960 barrels The owner or operator shall calculate monthly process rates based on the calendar month. Compliance with the annual throughput limits shall be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder shall calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 5. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the source. During periods of startup, process modification, or. adjustment of control equipment visible emissions shall not exceed 30% opacity for more than six minutes in any sixty consecutive minutes. Emission control devices subject to Regulation 7, Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation No. 1, Section II.A.1. & 4.) 6. This source is located in an ozone non -attainment or attainment -maintenance area and is subject to the Reasonably Available Control Technology (RACT) requirements of Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be conducted by submerged fill. (Reference: Regulation 3, Part B, III.E) 7. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) COLORADO Mr Pollution Control Division '?rpa=tment of Public F{ aiih x C, vrc*??-r en Page 2 of 7 8. o -r o.: 'rat. ha=''follow :ding procedures that minimize the leakage of VOCs to ed to (Reference: Regulation 3, Part B, III.D.2): • Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. • All compartment hatches at the facility (including thief hatches) shall be closed and latched at all times when loading operations are not active, except for periods of maintenance, gauging, or safety of personnel and equipment. • The owner or operator shall inspect onsite loading equipment during loading operations to monitor compliance with above conditions. The inspections shall occur at least monthly. Each inspection shall be documented in a log available to the Division on request. 9. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated and maintained so as to minimize leakage of volatile organic compounds to the atmosphere to the maximum extent practicable. OPERATING £t MAINTENANCE REQUIREMENTS 10. Upon startup of this point, the owner or operator shall follow the most recent operating and maintenance (OftM) plan and record keeping format approved by the Division, in order to demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to your O&M plan are subject to Division approval prior to implementation. (Reference: Regulation No. 3, Part B, Section III.G.7.) 11. The owner or operator of a loadout at which a dedicated flare is used to control emissions shall: a. Install and operate the vapor collection equipment to collect vapors during loading of tank compartments of outbound transport trucks and route these vapors to the dedicated enclosed flare. b. Include devices to prevent the release of vapor from vapor recovery hoses not in use. c. Use operating procedures to ensure that hydrocarbon liquid cannot be transferred unless the vapor collection equipment is in use. d. Operate all recovery and disposal equipment at a back pressure less than the pressure relief valve setting of transport vehicles. e. Inspect thief hatch seals annually for integrity and replace as necessary. Thief hatch covers shall be weighted and properly seated. f. Inspect pressure relief devices (PRD) annually for proper operation and replace as necessary. PRDs shall be set to release at a pressure that will ensure flashing, working and breathing losses are routed to the control device under normal operating conditions. g• Document annual inspections of thief hatch seals and PRD with an indication of status, a description of any problems found, and their resolution. COMPLIANCE TESTING AND SAMPLING COLOR ADO 3 Air Pollution Control Division a ¶ep=^mert of t 1.oho f loo f h is :':i=onm:nnt Page 3 of 7 12. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 13. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 14. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non -criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 15. 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. 16. 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. COLORADO Air Pollution Control Division II ,e.,: of Page 4 of 7 17. p P° i i 'ued r: nce u., the accuracy and completeness of information supplied y th- . n • 'op- . `. .' d is ditioned 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. 18. 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. 19. 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. 20. 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. 21. 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 orcriminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Andy Gruel, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Issued as Final Approval. COLORADO Air Pollution Control Division Page 5 of 7 Note •' i o r th= im: -if this p mit 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) 004 Benzene 71432 166 8 Toluene 108883 179 9 Ethylbenzene 100414 6 1 Xylenes 1330207 56 3 n -Hexane 110543 1495 75 2,2,4- Trimethylpentane 540841 11 1 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 004: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source N0x --- 0.000808 TNRCC Guidance Document CO --- 0.001614 V0C 0.1994 0.00997 AP -42 Ch.5.2 71432 Benzene 0.0004488 0.0000224 Engineering Calculation based on ProMax model 108883 Toluene 0.0004843 0.0000242 100414 Ethylbenzene 0.0000161 0.0000008 1330207 Xylene 0.0001508 0.0000075 110543 n -Hexane 0.004042 0.0002021 540841 2'2'4 Trimethylpentane 0.0000284 0.00000142 COLORADO Air Pollution Control Division ilzepanmcn: Hcz t g, .:. r':::ns Page 6 of 7 L = 12.46*S*P*M/T calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 6.2563 psia M (vapor molecular weight) = 52.434 lb/lb-mot T (temperature of liquid loaded) = 516.461 °R The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the mass fraction of each NCRP in the V0C (as modeled by ProMax) by the VOC emission factor. Controlled emission factors are based on a flare efficiency of 95%. N0x and CO emission factors were calculated using the TNRCC guidance document and a vapor flow rate of 2166.77 MMBtu/yr as modeled by ProMax. N0x and CO emissions are below APEN reporting thresholds and are not included on the permit. 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 (n -hexane and total) NANSR Synthetic Minor Source of: VOC 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 1 "ep- zrrtirs of PithC H*': h:r E,:i?rr�.msnc Page 7 of 7 1 „ Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] co r Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] E( Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information Request MODIFICATION to existing INDIVIDUAL permit (check boxes below) ®❑ ❑ Change company name Transfer of ownership ❑ ❑ Change process or equipment Change permit limit PE 701 Initial permit request for new facility Section 03 — General Information 0 ,-r ti 0 0 0 0 ) 0 O N C.) 0 0 C O L 3 Tz zz N I❑ . El El i C O CZ Normal Hours of Source Operation: C CU a) 0 0 a) R 0 0 0 0 W CZ 2 ❑ ❑ Q U .0 O O 0 a, CC C- El a) o Tcs" ❑ ®® > U .d O o 0 TU c" R 0 o C7 0 CZ a . 0 .0 0 0 O a 0 -- ro 0o O hl 0 C o o ,C.i 0 °0 0 0 ❑ °, an o U 5 o u 0a.Q-CI u0 a, z 0' :E-,› wW00N� CIoNZ ® "O n U o u Al F a cC, ns> O C a) U CO C U U C E a) a.) C O" a) •••• U cCG l H b • a) a a U R7 g c w R C ° a) " 0 d ;. a a w T O O O [b z 0 " y. O > O a Q\ en a) L', > .0 .z.:_c,,,© a) H aC 6 in W o U ON © 0 0 N ^d x .° ci y ° W __a„.) .. i. N ,.=a., A,. R 6 gin. a+ 3 U •G E c� h 'b ad : z .� U E 0 x C W c y s°J. CO ..u. p 0 O. cCd Q) u L .0 © Ca. ;m d 5 a R '4 = V] > T) = 3 6) o A .' U N 3 ,d a 0 .> O 04 «, % M y o ti zo C b0 b r--), y A �U144> •A '`� cC E`er 4,N R q 0 m o o a.U= ,..: = "o ..W oA= �O O .r cz O CC,1 0 v y O U y a 5•O 06> •u O a M d Ud... 0 Sr Wa^., r.Ue ,erA For guidance on how to complete this APEN form: 0 0 ��N M M CIN s 0\ C O 0 0 Mi (C, APEN forms: htt U C 0 C C fE 0 0 R a. fa 0 E O Q.w a� C � E C _a a w bbl O Cej it 0 0 a) b � 0 0 u C7 ID cd .0 .0 Requested Permit Limit: Condensate a) .0 ual While Controls Operational: Y. R a) .0 .0 O 0 0 h0 0 0 RVP of Sales Oil a) a) C0 U b External Floating Roof: Internal Floating Roof: El Fixed Roof: b0 a) Ca Date Of First Production (Month/Year) 0 N r. Installation Date of most recent storage vessel in storage tank (Month/Year) N WI Total Volume of Storage Tank (bbl) 5380 # of Liquid Manifold Storage Vessels in Storage Tank 0 ti Storage Tank m F Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) Newly Reported Well II ►'I ►'I►'I►rz1. Name of Well - Bihain 26F-232RD Bihain 26F-332 Bihain 26G-202 Bihain 26G-212 Bihain 26G-312 If API Number L 05-123-43263 05-123-42842 05-123-42844 05-123-42841 05-123-42843 N 0 a) 00 R FORM APCD-205 Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) H O ANN COGCC Website 0 O I) G0 W C"0 ° a0 ^_ o.42.1 9 -104.524790 mr CYC7 Cl) C. 7 aLJ z CC cn b it Ctl x v Cv ci u Cl) _ L) c 0o Other (Describe): ❑ ❑ Vertical with obstructing raincap 0 U Direction of stack outlet (check one): Width (inches) = Circular: Inner Diameter (inches) = Exhaust Opening Shape & Size (check one): Section 07 — Control Device Information E C, 4 x Cimarron 48", 1 x Cimarron 60" xm a) 0 0 ci .0 O 0 C 0 U W b a) C (J d 0 a; U Em El Make/Model Enclosed Combustor d0 Manufacturer Guaranteed: Waste gas heat content: e 0 ci C CT N VOC & HAP Control Efficiency: Pilot burner rating: cd H u W co 0 C O U C O w 0 u U 0 C) a) b 0 ai N s Annual time that VRU is bypassed (emissions vented): c O C a) U Q ❑ Closed loop system used for control of the storage tank(s) Description: E&P Sites Onl Information aration Technolo ad CID -o Section 08 — Gas/Li L CL C) CC CID O v, h 090 Cr c. o x � a) C) O 0 cn a) b0 C) .C b O 0 0 a) cen O C) Ir C' a U 0 C O c C c 0 u C) 3 Please describe the separation process between the well and the storage tanks: O E ✓ 0 ROi 0 0 w 0 0 E it 0 cia wl N C-) a; ci) 0. U Y C O C C 0 0 d .0 .04 0 .d C C C9 C u Ca 4 C i C Emission Factor Data Source CY a Er ProMax TCEQ ProMax O" ProMax ProMax ProMax ProMax Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions I Uncontrolled (Tons/Year) I Controlled (Tons/Year) 4.26 52.55 216.89 lb/yr 235.96 lb/yr 7.95 lb/yr (DM) r 75.01 lb/yr 1954.60 lb/yr 14 1.1 O WGA :0 N 4 z O O z 4337.89 lb/yr 4719.29 lb/yr 159.08 lb/yr (DM) 1500.20 lb/yr 39091.91 lb/yr 298.41 lb/yr Actual Calendar Year Emission' Uncontrolled (Tons/Year) I Controlled (Tons/Year) 4.26 In 8.50 216.89 lb/yr r 235.96 lb/yr 7.95 lb/yr (DM) 75.01 lb/yr 1954.60 lb/yr 14.92 lb/yr N kld V/NI Cq 0 VIN 4337.89 lb/yr 4719.29 lb/yr 159.08 lb/yr (DM) 1500.20 lb/yr 39091.91 lb/yr 298.41 lb/yr WI O 1-1 Emission Factor Uncontrolled Basis I Units lb/MMBtu lb/MMBtu Igq/gl II Please use the APCD 00 ,y 2.7126 0.276 10 kr)M © 0 O m* V 0 C N O 0 C 01 ,--I 0 O C O vJ 0 7 O O O O 0 0 0 0 0 0 Pollutant xON II CO 1 Benzene Toluene Ethylbenzene Xylenes n -Hexane u C C) '9',.) 0 U .� O E ~ E 4 N N Y C.1 cJ L tr O u C C u to. ti ci w 0 u C) 0 CC) CC CA a▪ + • 3 w eytl V ▪ ti aJ b R y C.) V ci CI) EHS Professional Elizabeth Duncan r E- C 0 a) y ro C 0 a) 7i • •N .a - O .C Q O • N of b QQ a) a) C a C C O O [ cct z! C G ti 0 yU c o • .9 5' O b C CL C/) • w W. N Ca O C O o d � � C °.) ° c m o u t CD '3 a) o 0 C C 0 N ci C ci C 0 0 C) .0 CU aa) C O a) C C W a) b O a h C O w 0 0 • qc -+ U C U -o O O 'C a 0. O C 0 U c C- O O A U U C a. U 0 .41 T Cd 0.C C4 09 b C .U. x C o0 U A d v a t U C c ci C O c ti C O 9 N C- U O C O C E U O i 9 c C O E U d P. C F s U FORM APCD-205 Hydrocarbon Liquid Loading APEN - Form APCD-208 Air Pollutant Emission Notice (APEN) and Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re -submittal. This APEN is to be used for Hydrocarbon Liquid Loading only. If your emission unit does not fall into this category, there may be a more specific APEN for your source. In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD) website at: www.colorado.00v/cdphe/apcd. This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: /'1W60090 AIRS ID Number: 113 / C1FOC,/�r L.L [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Bihain 26F-232, 332; 26G-202, 212, 312 Site Location: SWNW Sec 26 T5N R64W Mailing Address: (Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 E -Mail Address2: elizabeth.duncan@pdce.com Site Location County: Weld NAICS or SIC Code: 1311 Permit Contact: Elizabeth Duncan Phone Number: (303) 860-5800 'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear on all documents issued by the APCD. Any changes will require additional paperwork. 2 Permits, exemption letters, and any processing invoices will be issued by APCD via e-mail to the address provided. 357879 Form APCD-208 - Hydrocarbon Liquid Loading APEN - Rev 12/2016 1 AV COLORADO H.ulth 6 &.h.avrwm Permit Number: AIRS ID Number: / / [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 2- Requested Action 0 NEW permit OR newly -reported emission source ❑ Request coverage under traditional construction permit - OR - ❑ Request coverage under General Permit GP073 ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name ❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below) - OR- ❑ APEN submittal for update only (Blank APENs will not be accepted) - ADDITIONAL PERMIT ACTIONS - ❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE) Additional Info a Notes: Initial permit application for new facility 3 In addition to the APEN filing fee ($152.90), a General Permit fee of $250.00 will be assessed. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate loadout Facility equipment Identification: LOAD -1 For existing sources, operation began on: For new or reconstructed sources, the projected start-up date is: 11 /1 /2016 / / Will this equipment be operated in any NAAQS nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of (HAP) emissions? Does this source load gasoline into transport vehicles? Is this source located at an oil and gas exploration and production site? If yes: Does this source load less than 10,000 gallons of crude oil per day on an annual average? Does this source splash fill less than 6750 BBL of condensate per year? Does this source submerge fill less than 16308 BBL of condensate per year? O Yes ❑ No ❑ Yes 0 No ❑ Yes E No 0 Yes ❑ No 0 Yes ❑ No LI Yes ❑ No ❑ Yes O No Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 COLORADO 2 I Av Department ol xv n b Envl e.ru Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 4 - Process Equipment Information Product Loaded: ❑r Condensate ❑ Crude Oil ❑ Other: If this APEN is being filed for vapors displaced from cargo carrier, complete the following: Requested Volume Loaded5: } Requested values will become permit limitations. Requested limit(s) should consider future process growth 369,960 Bbl/yr 369,960 Bbl/yr This product is loaded from tanks at this facility into: (eg, "rail tank cars" or "tank trucks") Actual Volume Loaded: Tank Trucks If site specific emission factor is used to calculate emissions, complete the following: Saturation Factor: 0.6 Average temperature of bulk liquid loading: 56.461 ° F True Vapor Pressure: 6.2563 Psia 60 ° F Molecular weight of displaced vapors: 52.434 Lb/lb mol If this APEN is being filed for vapors displaced from pressurized loading lines, complete the following: Requested Volume Loaded5: 5 Requested values wilt become permit limitations. Requested limit(s) should consider future process growth Bbl/yr Bbl/yr Actual Volume Loaded: Product Density: Lb/ft3 Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 ®®COLORADO Health 6 F+'vVrnnm.n[ Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 5 - Geographical Information Geographical Coordinates (Latitude/Longitude or UTM) 40.371173 / -104.524790 =:' O erator P Stack ID°No �: Discharge Height ,; Above Ground Level .: (Feet). Temp ( F) T Flow Rate (ACFM)' Velocity (ft/sec) ,,t Indicate the direction of the stack outlet: (check one) ❑ Upward ❑ Horizontal ❑ Downward ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Other (describe): ❑ Upward with obstructing raincap Section 6 - Control Device Information ❑ Loading occurs using a vapor balance system Requested Control Efficiency ❑ Combustion Device: Pollutants Controlled: VOC, BTEX, HAPs Rating: MMBtu/hr Type: Enclosed Combustor Make/Model: TBD 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 ❑ Other: Pollutants Controlled: Description: Control Efficiency Requested: Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 COLORADO 4 oto<,c x.,1;n E &n oonrnont Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emission calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? Yes ❑ No If yes, describe the control equipment AND state the overall control efficiency (% reduction): Pollutant Control Equipment Description Overall Requested Control Efficiency (% reduction in emissions) PM SOX NO,, CO VOC Enclosed Combustor 95% HAPs Other: ❑ Using State Emission Factors (Required for GP07) VOC ❑ Condensate ❑ Crude 0.236 Lbs/BBL 0.104 Lbs/BBL Benzene n -Hexane 0.00041 Lbs/BBL 0.0036 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL From what year is the following reported actual annual emissions data? 2016 Use the following table to report the criteria pollutant emissions from source: (Use the data reported in Sections 4 and 6 to calculate these emissions.) Pollutant Uncontrolled Emission Factor Emission Factor Units Emission Factor Source (AP -42, Mfg. etc) Actual Annual Emissions Requested Annual Permit, , s' _ EmissionLimit(s ) ° Uncontrolled (Tons/year) Controlled6 (Tons/year) Uncontrolled (Tons/year) Controlled (Tons/year) PM SOX NO, 0.138 lb/MMBtu TCEQ N/A 0.15 (DM) N/A 0.15 (DM) CO 0.276 Ib/MMBtu TCEQ N/A 0.30 (DM) N/A 0.30 (DM) VOC 0.1994 lb/bbl ProMax 36.89 33.10 36.89 ;a:1-0. 1. Benzene 0.0004 lb/bbl ProMax 166.05 lb/yr (DM) 149.00 lb/yr (DM) 166.05 lb/yr (DM) 149.00 lb/yr (DM) Toluene 0.0005 lb/bbl ProMax 179.17 lb/yr (DM) 160.77 Ib/yr (DM) 179.17 lb/yr (DM) 160.77 Ib/yr (DM7 Ethylbenzene 1.61E-05 lb/bbl ProMax 5.95 lb/yr (DM) 5.34 lb/yr (DM) 5.95 lb/yr (DM) 5.34 lb/yr (DM) Xylenes 0.0002 lb/bbl ProMax 55.77 lb/yr (DM) 50.04 lb/yr (DM) 55.77 lb/yr (DM) 50.04 Ib/yr (DM) n -Hexane 0.0040 lb/bbl ProMax 1495.32 lb/yr 1341.73 lb/yr 1495.32 lb/yr 1341.73 lb/yr 2,2,4 Trimethylpentane 2.84E-05 Ib/bbl ProMax 10.50 lb/yr (DM) 9.43 Ib/yr (DM) 10.50 lb/yr (DM) 9.43 lb/yr (DM) Other: 5 Requested values will become permit limitations. Requested limit(s) should consider future process growth. 6Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank. gY Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 5I AV ,m He N6Frv.reubbc COLORADO Permit Number: AIRS ID Number: [Leave blank unless APCD has already assigned a permit # and AIRS ID] Section 8 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true and correct. l /z/zo (`7 Signature of Legally Authorized Person (not a vendor or consultant) Date Elizabeth Duncan EHS Professional Name (print) Title Check the appropriate box to request a copy of the: ❑✓ Draft permit prior to issuance ❑ Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with $152.90 and the General Permit registration fee of $250 as applicable to: Colorado Department of Public Health and Environment Air Pollution Control Division APCD-SS-B1 4300 Cherry Creek Drive South Denver, CO 80246-1530 Make check payable to: Colorado Department of Public Health and Environment Telephone: (303) 692-3150 For more information or assistance call: Small Business Assistance Program (303) 692-3175 or (303) 692-3148 Or visit the APCD website at: https://www.colorado.gov/cdphe/apcd Form APCD-208 -Hydrocarbon Liquid Loading APEN - Rev 12/2016 COLORADO 6 r 'sr' n
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