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Home My WebLink About20161763.tiffCOLORADO Department of Public Health & Environment Dedicated to protecting and improving the health and environment of the people of Colorado Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 May 31, 2016 Dear Sir or Madam: RECEIVED JUN 07 2016 WELD COUNTY COMMISs1ONt`-r1i'. On June 1, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for PDC Energy, Inc. - Churchill 28E-203. 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 2016-1763 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe /John W. Hickenlooper, Governor ; Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public Comment Website Title: PDC Energy, Inc. - Churchill 28E-203 - Weld County Notice Period Begins: June 1, 2016 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: Churchill 28E-203 Oil and gas production facility NENW Sec 28 T5N R64W Weld County The proposed project or activity is as follows: New production facility with sixteen (16) storage vessels storing condensate, and loadout of condensate from storage tanks to tank trucks. Emissions from the storage tanks are controlled by an enclosed combustor. 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 15WE1188 Et 16WE0501 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado. gov/pacific/cdphe/air-permit-public- notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Any such comment must be submitted in writing to the following addressee: Bradley Eades Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 cdphe.commentsapcd@state.co.us 1 I COLOR A.6O, IfiEFa Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Bradley Eades 337835 9/17/2015', 2/9/2016 Company Name: PDC Energy, Inc. County AIRS ID: 123 Plant AIRS ID: 9E11 Facility Name: Churchill 28E-203, 423... Physical Address/Location: NENW Sec 28, T5N, R64W Type of Facility: Exploration & Production Weil Pad What industry segment? Oil & Natural Gas Production & Processin Is this facility located in a NAAQS non -attainment area? Yes If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) Q Ozone (NOx & VOC) Section 02 - Emissions Units In Permit Application AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Hydrocarbon Liquid Loading No 15WE1188 1 Y`es Permit Initial Issuance " Newly reported emission source 002 Condensate. Storage Tank Yes 16WE0501 1 ;;:`res Permit initial ," Issuance Newly reported emission source Section 03 - Description of Project Application is being submitted for loadoutat a new E&P facility. Initial APEN {received 09/17/2015) was updated with APEN received 12/29/2015 which was also updated with APEN received (02/09/2016) to report that controls have been removed. In addition an application was submitted for condensate storage tanks (previously applied for GP01) to be added to a separate individual permit. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?" Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 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, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): VOC Title V Operating Permits (OP): VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Section 01- Adminstrative Information Facility AIRs ID: 123 9E11 [ 001 County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Loadout of hydrocarbon liquid', to tank trucks. Emission Control NuContrcl Device Description: Control Efficiency %: Section 02 - Emissions Inventory Analysis AP -42: Chapter 5.2 Equation 1 L = 12.46*S*P*M!T L = loading losses in lb per 1000 gallons loaded S = Saturation Factor P = true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T = temperature of bulk liquid loaded [deg. R] 1 degree Fahrenheit = 460.67 degree Rankine Criteria Pollutants Variables S P M T L 0.6 Submerged loading: dedicated normal service 5.9009 psia 51.205 lb/lb-mole 516.461 deg. R lb/10^3 gal lb/bbl 4.37 1.84E-01 Annual requested Throughput Annual requested VOC emissions 500,000 bbl/yr 21,000,000 Gallons per Year 1,:51 Pounds per Year 45.3 Tons VOC per Year Non -Criteria Reportable Air Pollutants/Hazardous Air Pollutants lb VOC/Ib Gas 0.7001896 Mass Ratio Uncontrolled (pounds Emission Emissions Are Emissions Com onent HAP/ ound VOC Factor lb/bbl lb r Re ortable? Benzene 0.2061 % 0.0005 270.31 Yes n -hexane 0.019 0.0051 2,532.03 Yes Toluene 0.003 0.0007 348.94 Yes Ethylbenzene 0.000 0.0000 7.87 No Xylenes 0.001 0.0002 91.83 NO 2,2,4-TMP 0.001 0.0002 90.51 No Section 03 - Regulatory Considerations Is this site considered an exploration and production location (e.g. well pad)? Yes If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) of crude oil per day 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.I Is this site located in an ozone non -attainment area? Yes If yes, this source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B Section III.D.2.a. This requirement may be met using "submerged fill" and/or vapor balance with emissions routed to an emissions control device. Is this facility classified as a major source of HAPs? No If yes, evaluate if 40 CFR, Part 63, Subpart EEEE "Organic Liquids Distribution" MACT provisions apply Does this facility involve the loading of refined crude/condensate in the form of "gasoline"? If yes, proceed to evaluate the following: Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a? If yes, the provisions of Regulation 7, Section VI.C.2 may apply Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? If yes, the provisions of Regulation 7, Section VI.C.3 may apply Section 04 - SCC Coding Emissions Factor Pollutant (lb/1,000 gallons) V0C 4.37 lb/1,000 gallons Benzene 0.01 lb/1,000 gallons n -hexane 0.08 lb/1,000 gallons Toluene 0.01 lb/1,000 gallons 40600132: Crude Oil: Submerged Loading (Normal Service) Use if S = 0.6 40600137: Crude Oil: Splash loading (normal Service) Use if S = 1.45 40600142: Crude Oil: Submerged Loading (balanced Service) Use if S = 1.00 40600145: Crude Oil: Splash loading (Balanced Service) Use if S = 1.00 and splash loading 40600148: Crude Oil: Submerged Loading (Clean tanks) Use if S = 0.5 Please select one SCC codes above based on the design and operation of your site. For these codes "Crude Oil" is a generic term that includes both condensate and crude oils. Delete SCC codes not used. Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 Section 01- Adminstrative Information Facility AIRs ID: 123 County 90.11 Plant 002 Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Emission Control Device Description: Requested Overall VOC & HAP Control Efficiency %: 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 = Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04- Emissions Factors & Methodologies 645,000`. Barrels (bbl) per year 645,000 Barrels (bbl) per year 645,000 Barrels (bbl) per year B'. Btu/scf 14.327 scf/bbl Will this storage tank emit flash emissions? Pollutant Condensate Storage Tanks Uncontrolled E.F. (Ibs/bbl Condensate Throughput) Controlled E.F. (Ibs/bbl Condensate Throughput) Uncontrolled E.F. (Ibs/MMBtu waste heat combusted) 2MEIMX.VIIILXV4XX*4671461N 1:56 !(:ZIMI.N.N.710467404XXVIOt INIIIMEMEMM Section 05 - Emissions Inventory 1.650E-04 2.100E-04 5.000E-06 7.500E-05 6.000E-05 Control Device Sixteen (16) 538 bbl liquid manifold'ves. s, used to store condensate, Emissions are controlled by Cimarron enclosed combustors with.. Control'. efficiency of 95%, Actual Condensate Throughput While Emissions Controls Operating = 29,420 MMBTU per year 29,457 MMBTU per year 29,457 MMBTU per year Uncontrolled E.F. (Ibs/bbl Condensate Throughput) Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NOX VOC CO 0.0 0.04 0.04 0.0 0.0 0.0 0.04 0.04 0.0 0.0 2.0 2.03 2.03 2.0 2.03 501.5 501.52 25.67 501.5 25.67 4.1 4.05 4.05 4.1 4.05 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 TMP 1.1E+00 1.1E+00 5.3E-02 1.1E+00 5.4E-02 1.4E+00 1.4E+00 6.8E-02 1.4E+00 6.9E-02 3.2E-02 3.2E-02 1.6E-03 3.2E-02 1.7E-03 4.8E-01 4.8E-01 2.4E-02 4.8E-01 2.5E-02 8.5E+00 8.5E+00 4.2E-01 8.5E+00 4.3E-01 3.9E-01 3.9E-01 1.9E-02 3.9E-01 2.0E-02 Section 06 - Regulatory Summary Analysis Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII, as provided bel Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section 011.0 Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, 0, C.1 & C.3, a Regulation 7, Section XVIl.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2, as provide Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSP5 Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH - If the tank is subject to a (See regulatory applicability worksheet for detailed analysis) Emissions Factor Source Citation 644,194'. 4 of 7 K:\PA\2015\15WE1188.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 Section 07- Initial and Periodic Semolina 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? _a 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 envisions 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? If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes Application orginally submittedwas requesting GP0l for these tanks. During review, a revised application was submitted to request cancellation of the GP and issuance of an individual construction permit Revised application included updated calculations for site -specific emission factor using a sample collected from Churchill 28E-203 site on 1/13/2016. The sample conditions were at a lower separator operating pressurethanthe sample originally submiteed. Per Liz Duncan, POChad the separators sampled . at : different operating conditions to minimizetheir flash emissions and decrease overall condensate tanks emissions. PDC will operatethe facility at the operatingcmsditions of the newer sample that these emissionsare based. -POCis reporting acutals, PTE, and Requested as the same value.Liz Duncan indicated via. emailthat 645,000 is a productionforecastwith a built in buffer. -Updated application recieved 02/09/16 indicate that portion of the actual throughput is uncontrolled. The requested control led emissions included this uncontrolled portion of throughput( 806 bbl/yr), however this request was initially denied since this would reflect an overall control efficiency less than 95% (whic h is required by XVII). It was suggested to POCto request a higher thoughput that would result in the requested controlled emissions with an overall control efficiency of 95%, L. Duncan amd K. Cox with'. PDC continued further discussion with Stefanie Rucker regarding conceresthat POC has with reporting an artificial throughput to arrive at the requested emissions. As a result and due to the relatively insignificant differences between reporting the portion of throughput as uncontrolled (vs reporting the total requested throughput at 95% control), the emissions in the permit reflect the throughput and`emisssions as represented on the APEN byPDC (644,194 bbl of the 645,000 bbl are controlled by 95%), The overall calculated control efficiency remains `95%.; -The secondary emisisonsfrom the control device are calculated usingthescf/bbl GOR from Hysys and a conservative heating va lue that was back calculated based onthe operators daculations for secondary emissions. The heating value used in the calculations above (3188 btu/scf) is conservativecomparedtothe heating value calculated byillysys (2442 btu/scf). Section 09 - Inventory 5CC Coding and Emissions Factors AIRS Point It 002 Process ii 01 5CC Code Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.15 0 lb/1,000 gallons condensate throughput VOC 37.0 95 lb/1,000 gallons condensate throughput CO 0.30 0 lb/1,000 gallons condensate throughput Benzene 0.08 95 lb/1,000 gallons condensate throughput Toluene 0.10 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.04 95 lb/1,000 gallons condensate throughput n -Hexane 0.63 95 lb/1,000 gallons condensate throughput 224 TMP 0.03 95 lb/1,000 gallons condensate throughput 5 of7 K:\PA\2015\15 W E1188.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to December 30, 2002 (CDPHE Memo 05-01)? 3. Are total facility uncontrolled V0C emissions greater than 5 TPY, NO0 greater than 10TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section li.D.3(? NA "Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? 2. Is the construction date (service date) prior to December 30, 2002 (CDPHE Memo 05-01)? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section II.D.2)? Yes Yea.'.'......;. 'Source requires APEN, is permit exempt Colorado Regulation 7, Section XII 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? 'Storage tank is subject to Regulation 7, Section XII, as provided below Section XII.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage Section XI I.C.2 — Emission Estimation Procedures Section XII.D — Emissions Control Requirements Section BILE — Monitoring Section %ILF — Recordkeeping and Reporting Colorado Regulation 7, Section 811.6 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC7 'Storage Tank is not subject to Regulation 7, Section x11.6 Section XII.G.2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment — Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station3 or natural gas processing plant? 2. Is this condensate storage tank a fixed roof storage tank? 3. Are uncontrolled actual emissions° of this storage tank equal to or greater than 6 tons per year VOC? Yis 'Storage tank is subject to Regulation 1, Section x Vll, 0, CI & C.3, as provided below Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVIl.C,3 - Recordkeeping Requirements 4. Does the condensate storage tank contain only "stabilized" liquids? if no, the following additional provisions apply. 'Storage tank is subject to Regulation 7, Section XVII.C.2, as provided below Section XVII.C.2-Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 5. Is this tank located at a transmission/storage facility? 40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m5) ("472 BBLs)? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4(? a. Does the vessel has a design capacity less than or equal to 1,589.874 m3 ["10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 00.111b? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of "storage vessel"' in 60.1116? 5. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b? [NV l Yes Yes .............. Yes....... Yes Source Req Source is Al Source Req Go to then Go to then Source is Su Go to then. Storage Tar Storage Tar Go to then Go to then Source is su Source is su Source is nl Go to then Storage Tar Go to then Go to then Go to the n 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa ['"29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ms (^950 BBL) and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.110b(b)]?; or c. The design capacity is greater than or equal to 75 Ms ["472 BBL] but less than 151 ms ['"950 861] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b)]? Storage Tank is not subject to NSPS Kb Subpart A, General Provisions §60.112b- Emissions Control Standards for VOC §60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §60.116b - Monitoring of Operations 40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Off and Natural Gas Production. Transmission and Distribution 1. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after August 23, 2011? 2. Does this condensate storage vessel meet the definition of "storage vessel"s per 60.5430? 3. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? 'Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per §60.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(c) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MALT HH, OR and Gas Production Facilities 1. Is the tank located at a facility that is major' for HAPs? 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end users (63.760(a)]3))? 3. Does the tank meet the definition of"storage vessel"' in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"' per 63.7617 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? Yes (Storage Tank is not subject to MAC? HH - tithe tank is subject to control provisions of NSPS 0000, the source must submit periodic reports per 63.775(e) Subpart A, General provisions per §63.764 (a) Table 2 §63.766 - Emissions Control Standards §63.773 - Monitoring §63.774- Recordkeeping §63.775 - Reporting Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control The use of non -mandatory language such as 'recommend, "may," 'should," and 'can,' is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must' and "required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Go to the n. Go to then Go to them Storage Tar Source is su The facility Go to then Go to then Source is su STATE OF COLORADO COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION TELEPHONE: (303) 692-3150 CONSTRUCTION PERMIT PERMIT NO: 15WE1188 Issuance 1 DATE ISSUED: ISSUED TO: PDC Energy, Inc. THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS: Oil and gas exploration and production facility known as the Churchill 28E-203 Facility, located in the NENW Section 28, Township 5N, Range 64W, Weld County, Colorado. THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING: Facility Equipment ID AIRS Point Description LOAD -1 001 Truck loadout of condensate. Emissions from the loadout are not controlled. 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 THOSE 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. (Reference: Regulation No. 3, Part B, 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 per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.) AIRS ID: 123/9E11 Page 1 of 7 f Public Health and Environment Air Pollution Control Division 3. 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 1. 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 NO x VOC CO LOAD -1 001 --- 46.0 --- Point See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits. Compliance with the annual limits shall be determined by recording the facility's annual criteria pollutant emissions, (including all HAPs above the de-minimis reporting level) from each emission unit, on a rolling twelve (12) month total. By the end of each month a new twelve-month total shall be calculated based on the previous twelve months' data. The permit holder shall calculate emissions each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. This rolling twelve-month total shall apply to all permitted emission units, requiring an APEN, at this facility. PROCESS LIMITATIONS AND RECORDS 2. This source shall be limited to the following maximum processing rates as listed below. Annual records of the actual processing rates 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 -1 001 Condensate Loading 500,000 BBL 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 3. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable) 4. 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) AIRS ID: 123/9E11 Page 2 of 7 t :f Public Health and Environment Air Pollution Control Division 5. The owner or operator shall follow loading procedures that minimize the leakage of VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B, III.D.2): a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking, or other liquid or vapor loss during loading and unloading. b. 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. c. 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. 6. 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 & MAINTENANCE REQUIREMENTS 7. This source is not required to follow a Division -approved operating and maintenance plan. COMPLIANCE TESTING AND SAMPLING 8. This source is not required to comply with any testing and sampling requirements. ADDITIONAL REQUIREMENTS 9. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation No. 3, Part A, II.C) a. 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 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. b. Whenever there is a change in the owner or operator of any facility, process, or activity; or AIRS ID: 123/9E11 Page 3 of 7 f Public Health and Environment Air Pollution Control Division c. Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or d. Whenever a permit limitation must be modified; or e. No later than 30 days before the existing APEN expires. GENERAL TERMS AND CONDITIONS 10. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 11. 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 No. 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. 12. 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. 13. 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. 14. 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. 15. 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. AIRS ID: 123/9E11 Page 4 of 7 f Public Health and Environment Air Pollution Control Division 16. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Bradley Eades Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. AIRS ID: 123/9E11 Page 5 of 7 f Public Health and Environment Air Pollution Control Division 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 (Reference: Regulation No. 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/agcc-reps 4) The following emissions of non -criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Point Pollutant CAS # Uncontrolled Emission Rate (lb/yr) Are the emissions reportable? Controlled Emission Rate (lb/yr) 001 Benzene 71432 270 Yes 270 n -Hexane 110543 2532 Yes 2532 Toluene 108883 350 Yes 350 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Pollutant Emission Factors - Uncontrolled lb/BBL loaded Source VOC 0.1840 AP -42 Benzene 0.0005 Mass Balance n -Hexane 0.0051 Mass Balance Toluene 0.0007 Mass Balance The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1 (version 1/95) using the following values: L = 12.46*S*P*M/T S = 0.6 (Submerged loading: dedicated normal service) P (true vapor pressure) = 5.9 psia M (vapor molecular weight) = 51.2 Ib/Ib-mol T (temperature of liquid loaded) = 516.461 °R AIRS ID: 123/9E11 Page 6 of 7 f Public Health and Environment Air Pollution Control Division The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by multiplying the VOC emission factor by the composition of each NCRP in the vapors (as calculated using Hysys and site -specific pressurized liquid sample. 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 facility is classified as follows: Applicable Requirement Status Operating Permit Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC MACT HH Major Source Requirements: Not Applicable Area Source Requirements: Not Applicable 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http: //ecfr. q po access. g ov/ 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 AIRS ID: 123/9E11 Page 7 of 7 Colorado Air Permitting Project Project Details Review Engineer: Package #: Received Date: Review Start Date: Section 01- Facility Information Bradley Eades 337835 , 9/17/2015 2/9/2016 Company Name: County AIRS ID: Plant AIRS ID: Facility Name: Physical Address/Location: Type of Facility: What industry segment? Is this facility located in a NAAQS If yes, for what pollutant? PDC Energy, Inc. 123 9E11 Churchill 28E-203, 423... NENW Sec 28, T5N, R64W Exploration & Production We Oil & Natural, Gas Production non -attainment area? ❑ Carbon Monoxide (CO) Section 02 - Emissions Units In Permit Application ocessing Yes ❑ Particulate Matter (PM) I] Ozone (NOx & VOC) AIRs Point # Emissions Source Type Emissions Control? Permit # Issuance # Self Cert Required? Action Engineering Remarks 001 Hydroca rbort Liq uzd Loadg; a ` 15WE1188 1 `des:: F erlltit Initial,-. Issuance ;;- Newly reported emission source 002 condensate Storage Tank Yes 16WE0501 1 Yes.. Permit initial ' . Issuance.... Newly reported emission source Section 03 - Description of Project Application is being submitted for loadout at a new E&P facility. Initial APEN (received 09/17/2015) was updated with APEN received 12/29/2015 which was also updated with APEN received (02/09/2016) to report that controls have been removed. In addition an application was submitted for condensate storage tanks (previously applied for GP01) to be added to a separate individual permit. Section 04 - Public Comment Requirments Is Public Comment Required? If yes, why?' Section 05 - Ambient Air Impact Analysis Requirements Was a quantitative modeling analysis required?2 )1Io 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, explain what programs and which pollutants here: Prevention of Significant Deterioration (PSD): VOC Title V Operating Permits (OP) VOC Is this stationary source a major source? If yes, explain what programs and which pollutants here: Section 01- Adminstrative Information Facility AIRs ID: 123 9E11 001', County Plant Point Section 02 - Equipment Description Details Detailed Emissions Unit Description: Loadout of hydrocarbon liquid to tanktruck Emission Control No Control_,,,, Device Description: Control Efficiency %: Section 02 - Emissions Inventory Analysis AP -42: Chapter 5.2 Equation 1 L = 12.46*S*P`M/T L = loading losses in lb per 1000 gallons loaded S = Saturation Factor P = true vapor pressure of liquid loaded [psia] M = molecular weight of vapors [lb/lb-mole] T = temperature of bulk liquid loaded [deg. R] 1 degree Fahrenheit = 460.67 degree Rankine Criteria Pollutants Variables S P M T L 0.6 Submerged loading: dedicated normal service 5.9009 psia 51.205 lb/lb-mole 516.461 deg. R 4.37 1.84E-01 Annual requested Throughput Annual requested VOC emissions lb/10^3 gal lb/bbl 500,000 bbUyr 21,000,000 Gallons per Year Pounds per Year 45. Tons VOC per Year Non -Criteria Reportable Air Pollutants/Hazardous Air Pollutants lb VOC/Ib Gas 0.7001896 Mass Ratio Uncontrolled (pounds Emission Emissions Are Emissions Com anent HAP/ ound VOC Factor lb/bbl lb r Re ortable? Benzene 0.2061 % 0.0005 270.31 Yes n -hexane 0.019 0.0051 2,532.03 Yes Toluene 0.003 0.0007 348.94 Yes Ethylbenzene 0.000 0.0000 7.87 No Xylenes 0.001 0.0002 91.83 No 2,2,4-TMP 0.001 0.0002 90.51 No Section 03 - Regulatory Considerations Is this site considered an exploration and production location (e.g. well pad)? Yes If yes, review the following two exemptions for applicability: Does the operator unload less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section 11.0.1.1 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 Is this site located in an ozone non -attainment area? Yes If yes, this source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B Section III.D.2.a. This requirement may be met using "submerged fill" and/or vapor balance with emissions routed to an emissions control device. Is this facility classified as a major source of HAPs? No If yes, evaluate if 40 CFR, Part 63, Subpart EEEE "Organic Liquids Distribution" MACT provisions apply Does this facility involve the loading of refined crude/condensate in the form of "gasoline"? If yes, proceed to evaluate the following: Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a? If yes, the provisions of Regulation 7, Section VI.C.2 may apply Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? If yes, the provisions of Regulation 7, Section VI.C.3 may apply Section 04 - SCC Coding Emissions Factor Pollutant (lb/1,000 gallons) V0C Benzene n -hexane Toluene 40600132 40600137 40600142 40600145 40600148 4.37 lb/1,000 gallons 0.01 lb/1,000 gallons 0.08 lb/1,000 gallons 0.01 lb/1,000 gallons Crude Oil: Submerged Loading (Normal Service) Use if S = 0.6 Crude Oil: Splash loading (normal Service) Use if S = 1.45 Crude Oil: Submerged Loading (balanced Service) Use if S = 1.00 Crude Oil: Splash loading (Balanced Service) Use if S = 1.00 and splash loading Crude Oil: Submerged Loading (Clean tanks) Use if S = 0.5 Please select one SCC codes above based on the design and operation of your site. For these codes "Crude Oil" is a generic term that includes both condensate and crude oils. Delete SCC codes not used. Section 05 - Emissions Inventory Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 Section 01- Adminstrative Information 123 9021 002 Facility Al Rs ID: - ' County Plant Point Section 02- Eauioment Description Details Detailed Emissions Unit Sixteen (16)538 bbl iquid manifold vessels used to store condensate. Description: Emission Control Device Emissions are controlled by Cimarron enclosed [brtrbustoK with a hydrocarbon tontrpl efficiency o€95%. Description: Requested Overall VOC & HAP Control Efficiency %: 95 section 03 - Processing Rate Information for Emissions Estimates Primary Emissions - Storage Tank(s) Actual Condensate Throughput = Requested Permit Limit Throughput = Potential to Emit (PTE) Condensate Throughput= Secondary Emissions - Combustion Device(s) Heat content of waste gas= 30884 Btu/scf Volume of waste gas emitted per BBL of liquids produced = 14.32T, cf/bbl Actual heat content of waste gas routed to combustion device = Request heat content of waste gas routed to combustion device = ;000'0 Barrels (bbl) per year Barrels (bbl) per year 645, Barrels (bbl) per year Potential to Emit (PTE) heat content of waste gas routed to combustion device = Section 04 - Emissions Factors & Methodologies Will this storage tank emit flash emissions? Pollutant Condensate Storage Tanks Uncontrolled E.F. (Ibs/bbl Condensate Throughput) Controlled E.F. (Ibs/bbl Condensate Throughput) PM2.5 \ \1 immEnsmiim 1.56 =ME 1 1.650E-04 2.100E-04 5.000E-06 7.500E-05 6.000E-05 Control Device Uncontrolled E.F. (lbs/MMBtu waste heat combusted) Actual Condensate Throughput While Emissions Controls Operating = 644,194'.. 29,420 MMBTU per year 29,457 MMBTU per year 29,457 MMBTU per year Uncontrolled E.F. (Ibs/bbl Condensate Throughput) Criteria Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) PM10 PM2.5 NOx VOC CO 0.0 0.04 0.04 0.0 0.0 0.0 0.04 0.04 0.0 0.0 2.0 2.03 2.03 2.0 2.03 501,5 501.52 25.67 501.5 25.67 4.1 4.05 4.05 4.1 4.05 Hazardous Air Pollutants Potential to Emit Uncontrolled (tons/year) Requested Permit Limits Uncontrolled Controlled (tons/year) (tons/year) Actual Emissions Uncontrolled Controlled (tons/year) (tons/year) Benzene Toluene Ethylbenzene Xylene n -Hexane 224 IMP 1.1E+00 1.1E+00 5.3E-02 1.1E+00 5.4E-02 1.4E+00 1.4E+00 6.8E-02 1.4E+00 6.9E-02 3.2E-02 3.2E-02 1.6E-03 3.ZE-02 1.7E-03 4.8E-01 4.8E-01 2.4E-02 4.8E-01 2.5E-02 8.5E+00 8.5E+00 4.2E-01 8.5E+00 4.3E-01 3.9E-01 3.9E-01 1.9E-02 3.9E-01 2.0E-02 - Reeulatory Summary Analysis Regulation 7, Section XII.C, D, E, F Storage tank is subject to Regulation 7, Section XII, as provided Gel Regulation 7, Section XII.G, C Storage Tank is not subject to Regulation 7, Section XII.G Regulation 7, Section XVII.B, C.1, C.3 Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, a Regulation 7, Section XVII.C.2 Storage tank is subject to Regulation 7, Section XVII.C.2, as provide Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6, Part A, NSPS Subpart 0000 Storage Tank is not subject to NSPS 0000 Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH - If the tank is subject to ci (See regulatory applicability worksheet for detailed analysis) Emissions Factor Source Citation 4 of 7 K:\PA\2015\15 W E1188.CP1.xlsm Condensate Storage Tank(s) Emissions Inventory Issuance Date: December 30, 2015 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 emisions 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 P5 Memo 05-01. Does the company request a control device efficiency greater than 95% for a flare or combustion device? If yes, the permit will contain and intial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 08 - Technical Analysis Notes -Application orginalfy submitted was, requesting SPOT for these tanksDuring review, a revised application was submitted to request. cancellation of the GP and issuance of an individual construction permit, Revised application included' updated calculations for site -spec. emission factor using a sample collectedfrom Churchill 28E-203 site on1/13/2026. The sample conditions were at a tower separator operating pressure than the sample originally submiteed. Per Liz Duncan, PDC had the separators sampled at different. operating conditions to minimize their flash emissions and decrease overall condensate tanks emissions. PDC will operate the facility at the operating conditions of the newer sample that these emissions are based. PDCN reporting acutals, PTE, and Requested as the same value. Liz Duncan indicated via email that 645,000 is a production forecast with a built in buffer. -Updated application recieved 02/09/16 indicate that a portion of the actual throughput is uncontrolled. The requested control led emissions included this uncontrolled portion of throughput( -806 bbl/yri, however this request was Initially denied since this would reflect an overall control. efficiency less than 95% (which is required by XVII) Itwas suggested>to PDC to request a higherthoughputthat m would result the requested controlled emissions with an overall control efficiency of 95%.. L. Duncan and It. Con with '<PDC c ontinued further discussion with Stefanie Rocker regarding cance trothat PDC has with reporting an artificial throughput. to arrive at the requested emissions. As a result and duet° the relatively insignificant differences between reporting the portion of thr° igfipu5 as uncontrolled (vs reporting the total requested throughput at 95% control), the emissions in the permit reflect the throughput and enisssions as represented on the APEN by PDC (644,194.hb1 of the 645,000 bbl are controlled by 95%). The overall calculated control efficiency remains `95%.: -The secondary emisisons from the control device are calculated using the scf/bbl GOR from.: Hysys and a ouraervative heating va lue that was back calculated based °lithe operators ciaculations for secondary emissions. The heating value used in the calculations above (31881rtul'scf) is cur ni ationcu pares to the heating value calculated by Hypes (2442 btu/scf). AIRS Point 8 Process U SCC Code 002 01 Section 09 - Inventory SCC Coding and Emissions Factors Uncontrolled Emissions Pollutant Factor Control % Units PM10 0.00 0 lb/1,000 gallons condensate throughput PM2.5 0.00 0 lb/1,000 gallons condensate throughput NOx 0.15 0 lb/1,000 gallons condensate throughput VOC 37.0 95 lb/1,000 gallons condensate throughput CO 0.30 0 Ib/1,000 gallons condensate throughput Benzene 0.08 95 Ib/1,000 gallons condensate throughput Toluene 0.10 95 lb/1,000 gallons condensate throughput Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput Xylene 0.04 95 lb/1,000 gallons condensate throughput n -Hexane 0.63 95 lb/1,000 gallons condensate throughput 224 TMP 0.03 95 lb/1,000 gallons condensate throughput 5 of 7 K:\PA\2015\15W E1188.CP1.xlsm Condensate Tank Regulatory Analysis Worksheet Colorado Regulation 3 Parts A and B ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.I.a)? 2. Is the construction date (service date) prior to December 30, 2002 (CDPHE Memo 05-01)1 3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.3)? NA NA ............... 'Not enough information NON -ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a(? 2. Is the construction date (service date) prior to December 30, 2002 (CDPHE Memo 05-01)? 3. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 5 TPY (Regulation 3, Part B, Section 11.0.2)? 'Source requires APEN, is permit exempt Colorado Regulation 7, Section XII 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station or natural gas drip station? 3. Is this storage tank located upstream of a natural gas processing plant? Yes Yes yes 'Storage tank is subject to Regulation 7, Section XII, as provided below Section XII.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section XII.C.2—Emission Estimation Procedures Section SILO — Emissions Control Requirements Section BILE — Monitoring Section XII.F — Recordkeeping and Reporting Colorado Regulation 7, Section XII.G 1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area? 2. Is this storage tank located at a natural gas processing plant? 3, Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC? No............... 'Storage Tank is not subject to Regulation 7, Section XII.G Section XII.G.2 - Emissions Control Requirements Section XII.C.1 — General Requirements for Air Pollution Control Equipment— Prevention of Leakage Section XII.C.2 — Emission Estimation Procedures Colorado Regulation 7, Section XVII 1. Is this condensate storage tank' located at an oil and gas exploration and production operation, well production facility', natural gas compressor station' or natural gas processing plant? 2. Is this condensate storage tank a feed roof storage tank? 3. Are uncontrolled actual emissions of this storage tank equal to or greater than 6 tons per year VOC? 'Storage tank is subject to Regulation 7, Section XVII, B, C.1 & C.3, as provided below Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions Section XVII.C.1- Emissions Control and Monitoring Provisions Section XVII.C.3 - Recordkeeping Requirements 4. Does the condensate storage tank contain only "stabilized" liquids? If no, the following additional provisions apply. 'Storage tank is subject to Regulation 7, Section XVII.C.2, as provided below Section XVII.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment 5. Is this tank located at a transmission/storage facility? 40 CFR, Part 60, Subpart Kb. Standards of Performance for Volatile Organic Liquid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (ms) (-472 BBLs]? 2. Does the storage vessel meet the following exemption in 60.111b(d)(4(? a. Does the vessel has a design capacity less than or equal to 1,589.874 ma ['10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfer' as defined in 50.111k? 3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984? 4. Does the tank meet the definition of `storage vessel' in 60.111b? 5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b? Yea Yes yes Yes Source Req Source is Al Source Req Go to the n Go to the n Source is su Go to the n. Storage Tar Storage Tar Go to then Go to then Source is su Source is nt Go to the n Storage Tar Go to the n Go to then Go to then 6. Does the storage vessel meet any one of the following additional exemptions: a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [-29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; or b. The design capacity is greater than or equal to 151 ma ["950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110b(b))?; or c. The design capacity is greater than or equal to 75 Ms ("'472 BBL] but less than 151 ms ["950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11ob(b)l7 'Storage Tank is not subject to NSPS Kb J Subpart A, General Provisions §60.112b - Emissions Control Standards for VOC t60.113b - Testing and Procedures §60.115b - Reporting and Recordkeeping Requirements §50.116b - Monitoring of Operations 40 CFR. Part 60. Subpart 0000. Standards of Performance for Crude Oil and Natural Gas Production. Transmission and Distribution 1. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after August 23, 2011? 2. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430? 3. Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transm soon and storage segment of the industry? 4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? 5. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart HH? Yea No No (Storage Tank is not subject to NSPS 0000 Subpart A, General Provisions per 660.5425 Table 3 §60.5395 - Emissions Control Standards for VOC §60.5413 - Testing and Procedures §60.5395(g) - Notification, Reporting and Recordkeeping Requirements §60.5416(e) - Cover and Closed Vent System Monitoring Requirements §60.5417 - Control Device Monitoring Requirements [Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if potential VOC emissions drop below 6 tons per year] 40 CFR, Part 63, Subpart MAR HH, Oil and Gas Production Facilities 1. Is the tank located at a facility that is major' for HAPs? 2. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria: a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))? 3. Does the tank meet the definition of "storage vessel"" in 63.761? 4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761? 5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000? 'Storage Tank is not subject to MAR HH - if the tank is subject to control provisions of NSPS 0000, the source must submit periodic reports per 63.7751e) Subpart A, General provisions per §63.764 (a) Table 2 §63.766- Emissions Control Standards §63.773 - Monitoring §63.774-Recordkeeping §63.775 - Reporting Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation, or any other legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend," 'may," "should," and "can,"is intended to describe APCD interpretations and recommendations. Mandatory terminology such as 'must" and 'required' are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself Go to the n. Go to then Go to then. Storage Tar Source is su The facility Go to then Go to then Source is su 16WE0501 Construction Permit Air Pollution Control Division Permit number: Date issued: Issued to: Facility Name: Plant AIRS ID: Physical Location: County: General Description: Issuance: 1 PDC Energy, Inc. Churchill 28E-203 Facilty 123/9E11 NENW SEC 28 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-1 002 Sixteen (16) 538 barrel fixed roof storage vessels used to store condensate 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. 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.) Storage Tank Version Syn Minor 2015- i Page 1 of 8 3. e all i ial compliance testing and sampling as required in this ermi d 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-1 002 --- 2.1 25.7 4.1 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-1 002 Enclosed Flare VOC and HAP PROCESS LIMITATIONS AND RECORDS 7. This source shall be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates shall be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.) Process Limits Facility Equipment ID AIRS Point Process Parameter Annual Limit TK-1 002 Condensate throughput 645,000 barrels The owner or operator shall monitor monthly process rates based on the calendar month. COLORADO Air Pollution Control Division cf-✓ub ::} 1eNi'.h. ;3 ,�yirrrtrr.�nC Page 2 of 8 throu I: put limits shall be determined on a rolling twelve (12) ont ' al. he .: each nth 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 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). 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, 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. COLORADO Air Pollution Control Division tie"panme":i Page 3 of 8 15. Upon startup of these points, 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 the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. The owner or operator shall demonstrate compliance with opacity standards, using EPA Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of visible emissions. "Visible Emissions" means observations of smoke for any period or periods of duration greater than or equal to one minute in any fifteen minute period during normal operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.16) Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Regulation Number 3, Part A, II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (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. 19. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at any such time that this source becomes major solely by virtue of a relaxation in any permit condition. Any relaxation that increases the potential to emit above the applicable Federal program threshold will require a full review of the source as though construction had not yet COLORADO Air Pollution Control Division Page 4 of 8 ce shall not exceed the Federal program threshold until a 3, Parts C and D). GENERAL TERMS AND CONDITIONS 20. 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. 21. 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. 22. 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. 23. 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. 24. 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. 25. 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. 26. 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. COLORADO Air Pollution Control Division ,Depumwrii.< f uttdw; Health „≤cony-::e,x. Page 5 of 8 de Permit Engineer Permit Histo Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. COLORADO Air Pollution Control Division snt•':i:r °Jk4kc Fixs' ;. a ^Ji-urir Page 6 of 8 No 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. AIRS Point Pollutant CAS # Uncontrolled Emissions (Ib/yr) Controlled Emissions (lb/yr) 002 Benzene 71432 2106 108 Toluene 108883 2686 138 Ethylbenzene 100414 88 5 Xylenes 1130207 979 50 n -Hexane 110543 16945 867 2,2,4- Trimethylpentane 540841 786 40 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 002: CAS # Pollutant Uncontrolled Emission Factors lb/bbl Controlled Emission Factors lb/bbl Source NOx --- 0.006 TNRCC-Flares and Vapor Oxidizers CO --- 0.012 VOC 1.555 0.078 ProMax3.2/Site Specific Sample 71432 Benzene 0.003 1.65E-4 108883 Toluene 0.004 2.10E-4 1330207 Xylene 0.002 7.50E-5 110543 n -Hexane 0.026 1.31E-3 540841 2'2'4 Trimethylpentane 0.001 6.00E-05 COLORADO Air Pollution Control Division Page 7 of 8 • factors .•r this point are based on the flare control efficiency of 95%. is `+ ':ct+"• x and '""'• ere calculated using 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 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 Dev w ,, Public lifnitr.is Page 8 of 8 N r W 07 M N Emission Source AIRS ID: [Leave blank unless APCD has already assigned a permit # & AIRS ID] Permit Number: [Provide Facility Equipment ID to identify how this equipment is referenced within your organization.] F Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information E L a .a d t CIO Cal W A Om L C ILI O W re d W 0) C7 0 ACD z 0 z t Q ca U L S W > a Z � 0 Ip _ arz❑a❑❑ ® ❑ ❑ d Change company name Change process or equipment C) w Transfer of ownership Change permit limit N O 00 o - a 0 U U o R. W N APEN Submittal for Permit Exempt/Grandfathered source 0 as C d z w = a 0 a EL 5.1 Z.)" a a) a) CZ O. 3 74 W = O > 'O Elizabeth Duncan Person To Contac dated site -s Emissions calculat Section 03 — General Information En CI) y -0 i° -0 0 C .0 -0 h N b C) U N O a a) N C- 0 0 m y 2 0 U L O C O 0 N 01 .. 10 C O C .0 C 0 r U O O C) I- C O pL O Normal Hours of Source Operation: Midstream or Downstream U O cn UC O rn eat bf) • U O a Q UU � O C N O w -o " m 0- [4 °' N 0 3 4. C) C) L O O p zZ00 ❑ ®® co0 O 0 y E� o A O 5 4...., 0 0. .0 .,.3 o 34) 0 rya Z or O W g C O 0€ U .0o 0 ?. 0 0 U .0 cal ea E H .9., g C) O .. 0 U w U . E H.a3- «+ y E> O ® U O c Csa Al ti C E •_ U E C a) O g C r.)at 0 0a)0 LO :+t° U e 0 0 = C g L D 000 O U C- C o• O � U ' oC 0.)o o X. Al E h pp .O N h O O Q. O U L C U O •w C) 6) ♦ ♦ c E C e w a. w 0) L a) 0 L O, O. 0 . _ > U �. O aL) — E >L"b .© c) aci N„ O E a) 0 L N t C pp W c° • a a `o L. C is 2 'C .� X ..O„ N 0 ' W �N....- =�7 H 0 'O ._.kos i N W ea U •° E o oo, 'fl ea A.7t • .� E C x W04) a}Ui a�i d C i C) a o G cod C) u y .0 o '. t fl ca c = O. = VD U p w > t >r 0 ,,,a,,, a) O 0O u) a 0� .0 a, O .'� O U > U� 3 C06 o Al o d L a = W a.) 3 E y ao . o ea L E I ca . .c 0 U E p R ea m Ca L O C a = E d z ° O. ,.y V Op O °) o C E U p +L+ W= a' 0. L C) ea o Lm o w E in sC°. A U aL)C oa > O gip;.. = OUo ba O .� , C c °. > dD O a O 0) p Ud�°3 E Wt= i=UQeA w O Oppv) r 7. M M M 01 01 01 Z M M M < J O O O u, 0 C APEN forms: httu :/A6 w NV. colorado. r) C ://www.colorado. Application status: htt 6 .0 .0 ON R Actual While Controls Operational: 0 v z 0 C E w Cc co H O s... O ea U I d G U 7 p0 c a 'i Gbp Q o v w V C 6 0 .0 j U F. H RVP of Sales Oil N External Floating Roof: Internal Floating Roof: Fixed Roof: Date Of First Production (Month/Year) Illn N O N Installation Date of most recent storage vessel in storage tank (Month/Year) In O N — Total Volume of Storage Tank (bbl) 00 O 00 00 # of Liquid Manifold Storage Vessels in Storage Tank b Storage Tank ID TK-1 Wells Serviced by this Storage Tank or Tank Battery (E&P Sites Only) i Newly Reported Well ■ ■ ■ ■ ■ Name of Well Churchill 28E-203 Churchill 28E-423 Churchill 28J-203 Churchill 28J-343 Churchill 28J-423 API Number 05-123-39751 O, cc 05-123-39750 05-123-39748 05-123-39749 O, M N .. O TK-I APEN.doc N 4r O C) CV FORM APCD-205 N O O H 0 O N tQ a E UCU) ccl oc;o w Q o o 0 o'^ r U c: a O N N 0 r, Er A m 1z C), °N93 • N C x� a O w Ca a Ca L � e F3 a Z a oQ w H C) .n C) L C) Width (inches) _ ❑ Horizontal ❑ Down O Other: Length (inches) = L b➢ O —y O > a O a E a Ca a 0 r.+ r^a) V/ Ca C) V) Cn Direction of stack outlet (check one): Section 07 — Control Device Information Section 08 — Gas/Li E&P Sites Onl Information aration Technolo h Ca 0 O C) a ao U a a .y a. Ca r•. O Ca a. U rn u =w O L 7 Ca U a. a) cd High/Low Pressure Separator ari y U tua C) C) U A y N U U O a. a a U O N C) U Ca Ca Q-1 NN Emission Factor Data Source a C..) F" o a,en TCEQ ProMax a a. ProMax ProMax a a ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 2.03 25.67 4.06 107.78 lb/yr 137.46 lb/yr 4.50 lb/yr (DM) 50.12 lb/yr 867.36 lb/yr 40.21 lb/yr V/AI (reaA/suo j) pailoiluooun 501.53 N/A 2105.59 lb/yr 2685.49 lb/yr 87.92 lb/yr (DM) 979.22 lb/yr 16944.95 lb/yr 785.47 lb/yr Actual Calendar Year Emission Controlled (Tons/Year) O N 25.67 4.06 107.78 lb/yr 137.46 lb/yr 4.50 lb/yr (DM) 50.12 lb/yr 867.36 lb/yr 40.21 lb/yr Uncontrolled (Tons/Year) z 501.53 Q z 2105.59 lb/yr 2685.49 lb/yr 87.92 lb/yr (DM) 979.22 lb/yr 16944.95 lb/yr 785.47 lb/yr Emission Factor Units = g az a g .a.a.a a Uncontrolled Basis M '� O � it) ,.4 0.276 0.0033 co cr O O co co O O O O 0.0263 O O O xON 1u1lnilod i1 VOC O U U N . Toluene a N p W Xylenes n -Hexane U a a a) a. T L E E N N N O N of O d Ca = _ a r 60 O C) a O o E E `> 6. O o u a s a O u O C° L Ca • CC 1, a � a a E d a IL L C O c w 'L 0.4 O L Ca c G E 6, ii c u u 1. L L O CI a a Ca CJ _ L ti c E a u Ca a a a u a. a. ea a) E a a O a E L 0 E a a �a a L a CI a a a O u a O a E L a a a L u u d s. u EHS Professional Elizabeth Duncan • E-0 - a+ � 1 .E o N h a •o a o a a C) • 7 O L rn U 'O N a.4 s a a Q o Ca a� O E o 2 4,74 w za-o w•N d0 a a V) O 7 N Ca O C C) C) -a aO a Ct a •o E v Ca a Ca U U a a 0 • a. O 0 P. L O W O a. C) a R R a CL4 a y ar .fl a C) N C) C) A C -oa a O U L A • N a I.U. a. Ca .Co a C) C) a. a c) a Ca C) cr a a Ca a E a U O C) a a E a n .a a a F a. W z a 0. L a a y P0 TK-1 APEN.doc N 0 N O a FORM APCD-205 E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form' Company Name: PDC Energy, Inc. Source Name: Churchill 28E-203, 423; 28J-203, 343, 423, 443; 28M-343, 443 Emissions Source AIRS ID2: 123 / 9E11 / 002 Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 39752 Churchill 28J-443 ❑ 05 - 123 - 39753 Churchill 28M-343 ❑ 05 - 123 - 39747 Churchill 28M-443 ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: 1 Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter N/A FEB -9 2016 Form APCD-212 TK-1 Appendix.docx 0 0 N FBI a I'H • E ii: E Ucz4 O g E. a eat a a) o a W cd O W 6" a) W�� 4= N Q C w s z2> §a 7 D � a H z 15WE1188 Permit Number: 0 N as a a a C r a U C a) w C a) a as O t a) 0 C E a a- u.) w a 0 J Facility Equipment ID: uested Action (Check applicable request boxes) Section 02 — Re Section 01 — Administrative Information General Permit GP07 Individual Permit PDC Energy, Inc. Company Name: CI) u L a O an C O N 0 L O a C C L 0 c z at a) a) 0 0 a a 0 a, L 0 0 0 u N O a a 0 n � a) ^O > w u O L E a E O. a) a 0,a UU z&) 28M-343, 443 H a a as a 0 re a 0 O u R v u a) u E L w a C at 0 z O h U I..�I O an a 0 c Change company name a) 75, O O Transfer of ownership DO Change process or equipment County: Weld Change permit limit Elevation: 4632 O U a`) a) E a d a d N U M 0 N 0 CO ai O U N Elizabeth.Duncan@pdce.com E-mail Address: E E 2 w E n &I) E E an z a Addl. Info. & Notes: Section 03 — General Information days/week 52 ea b 7 O C) Normal Hours of Source Operation: 0 N C) CO ai a) 0. a) O at -a a) U a) G. O u a, .f] 0 at 0. O a) a) Q 3 3 3 5 3 'C c 'a a "C Q Q Q Q Q CI CI DOD z z z z z ID I: EDE Q Q Q at a) a) E ❑ ❑ ❑ Loading of condensate from storage tanks to tank trucks 0 a 0. 'O C E a. a c a) O C 0 a. L U a .O at a) au C7 a) a) a.. 0. a) at a a a C O U O a GQ O an at a. rn a a- a) cd ii o �. o C � O T. '5a � a O p L7 oEna) O 0. 0 C bD b O d o U N 0"-'0 a N U`1.) c) a U M 71 u O 1-7 O t+ 4d u a O O N _ at O a) cal U O a a) 0 E a, vi U. > ai O O 0 at � H C".• C O at E z u • b U a) 0 a O a) a 0. E O" a A 0 y.a O E 4 ° a. cd a� oW, ,�-. E W aa 0 Q M M M •L .0 O. 6. a 7 W A . U JT T E M M M C o 0 0 o a" a�i VNi o •> -''I ea� Cw a » a ° w EI ca �Ca h Ul �7. O .7. 'y W .Z' A v' a)" u ._ 2 .sl s .a? U d 00 I.C.�V .`n. O} L C s L W a E -0 -o +, ad 3 ° u ° a ° E = Y " E > > w0 >i O 0. O 7 N a b0D O `-a r...) E C 0 d y > 3 a ≥ o >_ a) ov o 7 s. t) bL a- •L' O Q cCd L O O y O C y A "� U 3 0• a s > o ca cn E d y N 3�II d L a, .- 1:3 s L iN a A Q o > 7 i aua n c.) o00 o U[ 3' 'O '"' b O u a) i� a) ❑ C m Ca cu ° .. A L O U O O C 0. at W O M 'al U 0Ca 7 7 O a) s fl v�a. C.) c E al c L A U aL) a o z 0. E �.O�I Nkr. O M d o t.. E H aa):.. /69UQ�A w Q� ermitstatus Permit status: www.colorado a) a) rn �• L a - a) a) > y a. a .o ay+ O 0 .5 o Nd.- tc0 ro O a O a1 a) d G a at O N Q U ^at 0 1 rti A a L s O Condensate a) .0 .0 0 0 0 O 0 c ad a a w b a s a) — U a) cv r a a a o u a- L as u O bo 0 E O O 17 0 a) 0 c6 acol �, �•e at L O a R w 0 a) rl!a 14 ZW a -a 7 et ° • > y O c a. A cu cal 0 a) y at a) a as Tank Trucks O C a) .12 ad a E O U at O U a b O O. C a) a) a E O N 0 L W a) .76 a) a) a 0 z_ O y E a) a) 7 u as O ^O a L O .y E u a) a a) E 0 a m O In co O O N 1.0 at 0 cal a) a) a. Ca w 0 tat 3 a U 0 w 0 arc Q C) O 0 C1 ui True Vapor Pressure: C a) oD Q C b w a) .a y i+ T Y coi 01) 0 C a) a a 17 NN U at a) O. E d O u, a) 0 0 a as • a) a G z W a) a) as Loads per year: a a U a w O O U 2 cn d2/chp5/index.hhu u�/IIn/chief/: CV M FORM APCD-208 U O '7 O a) 0 'o a C O at 0 O 00 a. N 0 U a N w 0 a) a) uid Loadin 0 O w O) eh N a U) 41 U) O 5 CO CO w U, Permit Number: Section 06 —Stack (Source, if no combustion) Location (Datum & either Lat/Long or UTM) Section 05 — Stack Information (Combustion stacks must be listed here) a rn o 0 N co a_ 0) Co U) r -- co O -104.55717 op cn U U N a) L_ O El o wv E EC) Width (inches) = 3 II Q 6 I o O El C O cn W C) U C CO C C U C O CO U a) Direction of stack outlet (check one): II N C) U C .u+ CO Section 07 — Control Device Information Section 08 — Emissions Inventory Information O 0 O O 0 0 �- OO O O 0 0 N N ww E CC %Q =caa �aa C w R C O N I O O O U U 2. O O ii a C `" O O d d C 7 W U U C) I II Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007): Emission Factor Documentation attached (If using site specific emission factor) Estimation Method or Emission Factor Source x al 0 a` ProMax ProMax Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above. Requested Permitted Emissions Controlled (Tons/Year) 45.93 270.31 lb/yr 2532.03 lb/yr Uncontrolled (Tons/Year) 45.93 270.31 lb/yr 2532.03 lb/yr Actual Calendar Year Emissions5 Controlled (Tons/Year) 45.93 270.31 lb/yr 2532.03 lb/yr Uncontrolled (Tons/Year) el rn d 270.31 lb/yr 2532.03 lb/yr Emission Factor Units _ Uncontrolled Basis 0.1837 LC) LO O O O d Control Efficiency (% Reduction) Identify in Section 07 Control Device Description Secondary N 0. Pollutant XON VOC CO 4u C 4 N 4 U CQ .00 L C N 0. E O C 00 O 4.. w, o C C O CL ILI O. - eC = CA O ws r u CO 3 s ^O w �; 3 .. y E C .o R G h C. O L. so w u E C E w L b0 4. C G e y^O E ^v .+ C et C ea L W = C. ° a d d Z O ^D d C C C T.) = RO w u C u C L C y. = .2C O E . d L co, W 7,4 C: a' C C.' Cs = CO _ea -0,, _l'.' - L ' et _.> d .O+ w y Y Z a p .!2:6 .>' V 0. o .:„..,a© a.%ads E = u .. L .' E w = L a) z u u L ►ti 0. W a d r ~ L i:l C7 L a 4. O ;o d o ' E W L >a U L G •3 O 4. up. m u w .o u .r Y. CO `0 w d a) L d C A ? _ +• aa) v = OO L E L C) L A= w u ^O E 1° ye C =0 0 o Y¢. � do h a O1 0 O L u s o > U , u alu L r%, w EHS Professional Elizabeth Duncan Name of Legally Authorized Person (Please print) FormAPCD-208-HydrocarbonLiquidLoadingAPEN-Ver.4-14-2014 (1).docx N O N a) CO a Hello