HomeMy WebLinkAbout20203837.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758
Greeley, CO 80632
December 7, 2020
Dear Sir or Madam:
RECEIVED
DEC 21 2020
COOMMISSIONERS
On December 8, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
PDC Energy, Inc - Gillham 18 Sec HZ. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Potts, Governor I Jill Hunsaker Ryan, MPH, Executive Director
P�bl lG Rev e( -J
cc:PV(TP) Ht-Ostat),P(43)A/ER/cN/00,
o6(sr)
01/06/al i2/2q /20
2020-3837
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc - Gillham 18 Sec HZ - Weld County
Notice Period Begins: December 8, 2020
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: Gillham 18 Sec HZ
Well Production Facility
SESE quadrant of Section 18, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc wishes to reduce requested permitted
emissions by reducing requested condensate throughput.
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):
• The source is requesting a federally enforceable limit on the potential to emit in order to avoid
other requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0042 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. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
(COLORADO
Department of Public
Health 6 Environment
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE0042
XX/XX/XXXX
PDC Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance:
Gillham 18 Sec HZ
123/9F86
SESE SEC 18 T5N R64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
2
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-1
001
Twenty (20) 538 barrel fixed roof liquid
manifold storage vessels used to store
condensate
Enclosed Combustors
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 must 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/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must 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
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4. )
3. The operator must 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
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NOX
VOC
CO
TK-1
001
---
1.3
15.0
2.8
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Compliance with the annual limits for criteria pollutants must 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 must calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
6. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-1
001
Enclosed Combustor
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must 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
Page 2 of 9
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment ID
AIRS
Point
Process
Process Parameter
Annual Limit
TK-1
001
01
Condensate Throughput
255,980 barrels
02
Combustion of pilot
light gas
1.5 MMscf
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must 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 must 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)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for 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, Part D, Section I.C.) (State only enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.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 II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; 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 schedule in Regulation Number 7,
Part D, Section II.B.2.d.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division -approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C.for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must 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 OftM 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. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
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. All previous versions of this permit are cancelled upon issuance of this permit.
19. A revised Air Pollutant Emission Notice (APEN) must 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
Page 4 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NO),) 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.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must 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
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D)
GENERAL TERMS AND CONDITIONS
21. 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.
22. 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.
23. 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
Page 5 of 9
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
24. 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.
25. 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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must 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.
26. 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.
27. 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: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
May 30, 2018
Issued to PDC Energy, Inc.
Issuance 2
This Issuance
Issued to PDC Energy, Inc. Operator reduced
permitted emissions by reducing requested
condensate throughput.
Page 6 of 9
COLORADO
Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 must 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 must 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-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
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
1281
64
Toluene
108883
1729
86
Ethylbenzene
100414
63
3
Xylenes
1330207
780
39
n -Hexane
110543
11172
559
2,2,4-
Trimethylpentane
540841
57
3
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:
Process 01: Condensate Throughput
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
9.97x10-3
9.97x10-3
TNRCC and Promax
CO
1.99x1O'
1.99x10-2
TNRCC and Promax
VOC
2.350
1.175x10-'
Promax
71432
Benzene
5.003x1O3
2.501x10-4
Promax
Page 7 of 9
r •1M
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
108883
Toluene
6.755x10-3
3.378x10-4
Promax
1330207
Xylene
3.048x10-3
1.524x10-4
Promax
110543
n -Hexane
4.364x10-2
2.182x10-3
Promax
Note:
The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific VOC
and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax
simulation. The site specific sample used in the ProMax simulation was obtained from the Gillham 18Y-202
well on 12/19/2017. The NOx and CO TNRCC emission factors (0.1380 lb/MMBtu and 0.2755 lb/MMBtu
respectively) were converted to units of lb/bbl using a heat content of 2565.4 Btu/scf, molecular weight of
45.7 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, and a VOC mol% of 69.2%. Actual emissions
are calculated by multiplying the emission factors in the table above by the total condensate throughput.
Process 02: Combustion of pilot light
CAS #
Pollutant
Uncontrolled Emission
Factors
lb/MMSCF
Source
NOx
77.2
AP -42 Chapter 13.5
VOC
6.1
AP -42 Chapter 1.4
Table 1.4-2
CO
352.2
AP -42 Chapter 13.5
Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP -42 Chapter 13.5
NOx and CO emission factors (0.068 lb/MMBtu and 0.310 lb/MMBtu respectively) by a heat value of 1,136
Btu/scf.< The VOC emission factor in the table above was obtained by multiplying the AP -42 Chapter 1.4
emission factor by a heat value of 1,136 Btu/scf. Actual emissions are calculated by multiplying the emission
factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a
constant rate of 15.6 scf/hr. There are a total of eleven (11) combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 171.6 scf/hr.
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 must 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. True Minor Source of CO, NOx,
Et HAPs.
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PSD
True Minor Source of: CO Et NOx
NANSR
Synthetic Minor Source of: VOC.
MACT HH
Area/Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http: / /www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
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 X 000O(
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Diego Chimendes
427152
7/16/2020
10/1/2020:.
Section O1- Facility Information
Company Name: PDC Energy,Inc.
County AIRS ID: 123
Plant AIRS ID: 9F86
Facility Name: Gillham 18 Sec HZ
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
SESE quadrant of Section 18, Township 5N, Range 64W
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRS Point #
(Leave blank unless APCD
has already assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
(Leave blank unless
APCD has already
assigned)
Issuance
#
Self Cert
Required?
Action
Engineering
Remarks
001
Storage Tank
TK-1
Yes
18WE0042
2
Yes
Permit
Modification
Yes
Ozone (NOx & VOC)
Quadrant
Section
Township
Range
SESE
18
5N'
64
Section 03 - Description of Project
PDC Energy, Inc. (PDC) submitted an application requesting modification of permit'18WE0042. PDC wishes to reduce requested permitted emission by reducing
requested condensate throughput.
This point source is+APEN-required because uncontrolledVOC emissions are greater than 1 tpy and uncontrolled emissions of at least one non -criteria pollutant is
greater than 250 tpy. (Regulation 3 Part A Section 11.8.3.) Point source is permit -required because uncontrolled facility -wide VOC emissions are greater than 2 tpy.
(Regulation 3 Part B Section ILD.2.).
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of thesource in order to
avoid other requirements. (Regulation 3 Part 8 Sections IILC.1.d.).
Point source is not subject to ambient air impact analysis. (Regulation 3 Part D Section II.A.44).
Sections 04, 05 & 06- For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit -
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Yes
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
No
Yes
SO2 NOx CO
Is this stationary source a major source? No
VOC PM2.5 PM10 TSP HAPs
J
J
❑ ❑
Colorado Air Permitting Project
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
S02 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑
Tenk(s) Emissions Inventory
Section OS - Administrative Information
!Facility Allis ID:
123
County
9F8B
Plant
001
Paint
Section 02 - Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit Twenty (20) 538 barrel fixed roof, liquid manifold condensate storage vessels. `
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Ten (10) Omar.. 48" & one(1)Cimarron 60" enclosed combustors.
Primary Emissions -Storage Tank(s)
Actual Throughput=
Requested Permit Limit Throughput=
95.0
213,313.0 Barrels (bbl) per year
255,980.0 Barrels (661) per year
Requested Monthly Throughput= 21740.8 Barrels (bbl) per month
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
Molecular Weight=
VOC mai%
Molar Volume =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
255,980.0. Barrels (hbl) per year
2565.4 Btu/scf
scf/bbl
45.7.16/Ibmol
69.17%
379.4. scf/ibmol
Potential to Emit (PTE) heat content of waste gas routed to combustion device=
Control Device
15,415.5 MMBTU per year
18,498.8 MMBTU per year
18,498.8 MMBTU per year
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Emission Factor Source
- Pollutant
Uncontrolled Controlled
(Ib/bbl) (Ib/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
2.35E+00
1.175E-01
5'tF Ike ,. - - „x ,
Benzene
5.003E-03
2.501E-04
Toluene
6.755E-03
3.378E-04
Ethylbenzene
2.477E-04
1.239E-OS�;
Xylene
3.048E-03
1.524E-04
n-Hezane
4.364E-02
2.182E-03
224 TMP
2.226E-04
1.113E-05
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
5.38E-04
FSTeble l4-2(PF�'11 yppit�.5
,.
-
&CC Fla re EF(irS5ien5 Gurdaote OX)
RCC Flare Ernisac, Geld ance{COj
PM2.5
0.0075
5.38E-04
SOx
0.0006
4.25E-05.�
NOx
0.1380
9.973E-03
CO
0.2755
1.991E-02
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf)
(Pilot Gas Heat
Combusted)
(Pilot Gas
Throughput)
PM30
0.0075
8.5
'.-42Table 1.4-Y(PM10/PM.2.5).
F=q2 Table 1.42 ( PM 10/PM.2.5)
-42 Table 1.4-2(50x)
=A2 Chapter 13,5 Industrial rlares(Nox)
PM2.5
0.0075
8.5
SOx
0.0006
0.7
NOx
0.0680
77.2
VOC
0-0054
6.1
„+F2 Table .1 (VOC) i
.` 2 Chap ,.S.Industreal Flares (CO}
CO
0:3300
352.2
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tans/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
- 0.1
0.1
0.1
0.1
0.1
12.8
0.1
0.1
0.1
0.1
0.1
12.8
0.0
0.0
0.0
0.0
0.0
1.0
1.3
1.1
1.1
1.3
1.3
226.7
300.7
250.6
12.5
300.7
15.0
2554.4
2.8
2.4
2.4
2.8
2.8
477.8
Potential to Emit
Actual Emissions
Requested Permit Limits
3 of
KAPA\2018\18WE0042.CP2
Storage Tank(s) Emissions Inventory
Hazardous Air Pollutants
Uncontrolled
(Ibs/year)
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
1280.6
1067.1
53.4
1281
64
1729.2
1441.0
72.1
1729
86
63.4
52.8
2.6
63
3
780.2
650.1
32.5
780
39
11172.0
9309.9
465.5
11172
559
57.0
47.5
2.4
57
3
4 of 9 IC\PA\2018\18W E0042.CP2
Storage Tank(s) Emissions inventory
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Part D,Section LC, D, E, F
Storage tank is subject to Regulation 7, Part D, Section I.C-F
Regulation 7, Part O,Section I.G, C
Storage Tank is not subject to Regulation 7, Section I.G
Regulation 7, Part D,Section II.B, Cl, C.3
Storage tank is subject to Regulation 7, Part D, Section 11, B, C.1 & C.3
Regulation 7, Part D,Section II.C.2 -
Storage tank is subject to Regulation 7, Part 0, Section II.C.2
Regulation 7, Part D,Section II.C.4.a.(i)
Storage Tank is not subject to Regulation 7, Part D, Section II.C.4.a(i)
Regulation 7, Part D,Section II.C.4.a.(ii)
Storage Tank is not subject to Regulation 7, Part D, Section II.C4.a(ii), b - f
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.
NSPS Subpart 0000a
Storage Tank is not subject to NSPS 0000a
Regulation B, Part E, MACT Subpart HH
Storage Tank is not subject to MACE HH
(See regulatory applicability worksheet for detailed analysis)
Section 07- Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks, does the company use the state default emissions factors t
estimate emissions?
If yes,. are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy7
If yes, the permit will contain an 'Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample
should be considered representative which generally means site-specifc 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 14-03.
Does the company request acontrol device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
1. Site specific Emission Factors: The site specific sample used to establish emissions factors for this source was obtained within a. year of the first issuance application. The sample was obtained from the Giliham 18Y-
202 well. This well is one of the ten drilled at this facility and there were no significant changes to the facility since the dwelopment of the emissions factors. As a result, the permit will not require initial testing in
order to obtain a new site specific sample. It should be noted that the sample. includes sample probe temperature and pressurein conjunction with gauge pressure and temperature.
2. Secondary Emissions Calculations:
2.1 Operator used the following equation to calculate the annual heat input
Heat Input (MM Btu/ yr) _ [Uncontrolled VOC (ton/yr)j * [2000(lb/ton)] +MW (lb/lbmol) + [379.41(scf/lbmol)]. [i/VOC mol96] • [Heat Content (Btu/scf)] •�[1MMBtu/(1000;000 Btu)].
The values used in the equation were obtained from a ProMax simulation used to calculate emissiona and develop emission facto-. The values used are as follow: (i) Molecular weight: 45.71b/lbmol, (ii) VOC
69.2%, (lid Heat Content: 2565.48tu/scf....
3. Pilot Light. Emissions Calculations Operator assumed pilotfuel to have the same conditions of field gas which is consistent with the plant design provide by operator. The permit will not contain initial or periodic
' opacity testing for the enclosed combustor(s)because the 0&M plan approved for this source requires weekly visible emrssronsobservations of the enclosed combustor(s)
A throughput limit is includedin the permit for pilot combustion. Emission factors and calculation methods for pilot light c ombustjon emissions are also included In the notes to permit holder. This..
information is included in the permit because pilot light emissions contribute to the overall emissions from this source. Addtionally it is important to include this information because throughput tracking and emission
calculation methods are different than those used to estimate emissions based on the condensate throughput.; This clarity is mportant for accurately quantifying actual emissions at this facility.
4. Operator submitted self -certification on (11/05/2018. Division approved self-cert on 11/07/2018.
5. Permit draft was provided tooperator who had two comments. (I) operatorasked to update the facility name and (ii( operator asked to correct emission factors source used to calculate NOx and CO emissions from
combustion device. Both issues were corrected and final permit draft was sent to operator. -
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point tt
001
Process tt
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control% Units
PM10 0.01 0 lb/1,000 gallons Condensate throughput
PM2.5 0.01 0 lb/1,000 gallons Condensate throughput
SOx NEM 0 lb/1,000 gallons Condensate throughput
NOx 0.25 0 lb/1,000 gallons Condensate throughput
VOC 55.93 95 lb/1,000 gallons Condensate throughput
CO 0.52 0 lb/1,000 gallons Condensate throughput
Benzene 0.12 95 lb/1,000 gallons Condensate throughput
Toluene 0.16 95 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons Condensate throughput
Xylene 0.07 95 lb/1,000 gallons Condensate throughput
n -Hexane 1.04- 95 lb/1,000 gallons Condensate throughput
224 7M 0.01 95 lb/1,000 gallons Condensate throughput
5 of KAPA\2018\18WE0042.CP2
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Re: ulation 3 Parts A and B -APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutantsfrom this Individual source greater than 2 TPY (Regulation 3, Part A, Section ILD.l.a)?
2. Is the construction date (service date) prior to 11/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Aretotal facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10TPY or CO emissions greater than SOTPY(Regulation 3, Part B, Section ll.D.3)?
IYou hnvc Indicated that source & inche Nm. nttan:ment Area
NON -ATTAINMENT
1. Are uncontrolled emissionsfram any criteria pollutants from this individual source greater than 1TPY(Regulation 3, Part A, Section 110.1.07
2. Is the construction date (service date) prior to 12/30/2002 and not mod0ed after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2for additional guidance on grndfather applicability)?
3. Are total fadlhy uncontrolled VOC emissions greater than 2TPY, NOx greater than 5 TPY or CO emissions greater than to TPY (Regulation 3, Part B, Section ll.D.2)7
kmurcE requimsa Penult
Colorado Regulation 7. Part D. Section I.C-F &G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D, Section IA.1)7
2. Isthis storage tank located at oil and gas operations that collect,store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section LAM?
3. Is the storage tank located at a natural gas processing plant (Regulation 7, Part D, Sertion 1G)7
4. Does this storage tank contain condensate?
5. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids] emissions (Regulation 7, part 0, Section l.G.2)7
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section l.D.3.a(II))7
Storage( -auk is sublet! In Reisii,c
Part D, Section I.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
PartD, Section I.C.2—Emission Estimation Procedures
Part 0, Section I.0 —Emissions Control Requirements
Part D, Sexton LE —Monitoring
Part 0, Section LE —Recordkeeping and Reporting
!Source Requires an APEN. Go to
Part D, Sexton LG.2- Emissions Control Requirements
Part 0, Section I.Cl.a and b —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Colorado Regulation 7, Part D, Section II
1. Is this storage tank located at a transmission/storage facility?
2. Isthis staragetank' located at an oil and gas exploration and production opera!Ion, well production facility', natural gas compressor stations or natural gas processing plant"(Regulation 7, Part%Section lLC)?
3. Does this storage tank have a fixed roof (Regulation 7, Part&Section ll.A.20)?
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section ll.Gl.c)7
Part D, Section ll.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, Section II.C.1- Emhsians Control and Monitoring Provisions
Part 0, Section II.G3 - Recordkeeping Requirements
5. Does the storage tank comain only "stabilized.' liquids (Regulation 7, Part D, Section ll.G2.6]?
Yeesa,'i
Yes
PM
Go to next question
Source Requires a permit
Source Requires an APEN. Go to
Go to next question
Source Requires a permit
Continue - You have indicated eh
Continue -You have indicated th
Storage Tank a not subject to RE
Continue -You have Indicated th
Go to the next question - You ha
Go to the next quesion
Source is subjert to parts of Reg,
Source is subject to all provision:
Part O, Sexton ll.C.2 Capture and Monitoring for Storage Tanks fined with Air Polluton Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1, 2020 or located at a facility that was modified on or after May 3, 2020, such
6. that an additional controlled storage vessels constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section ll.C.4.a(i)? vc ...:.::.Storage Tank is not subject to RE
Is the controlled storage tank located at a well production facility, natural gas compressorstation, or natural gas processing plant constructed on or afterlanuary 1, 2021 or located at a facii@ythat was modified on or after January 1,
7. 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase inthroughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section II.G4.a.(il)7
40CFR Part 60 Subpart Kb. Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greaterthan or equal to 75 cubic meters (m'I 1-472 BBLs] (40CFR 60.110b(a))7
2. Does the storage vessel meet the following exemption In 60.3316(d)(4)7
a. Does the vessel has a design capacity less than or equal to 1,589.874 m'(-10,000 BBL) used for petroleum' or condensate stored,processed, or treated priorto custody tmosfer'as defined in 60.11167
3. Wmthis storage vessel cons[ructed, recanstrurted, or modified (see definitions 40CFR, 60.2)after July 23, 1984 (40 CFR 60.1106(a))7
4. Does thetank meet the definition of"storage vessel"' in 60.111b?
5. Does the storage vessel store a"volatile organic liquid(VOL)"s as defined In 60.11lb?
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 tothe atmosphere (60.110b(d)(1))?; or
b. The design capacity is greaterthan or equal to 151 me [-950 BBL] and stores a liquid with a maximumtrue vapor pressure' less than 35 kna (60.110b(b]]7; or
c. The design capacity is greaterthan or equal to 75 M31-472 BBL] but less than 151 ms (-950 BBL] and stares a liquid with a maximum true vapor pressure' less than 15.0 kna(60.130b(b))7
Does the storage tank meet either one of thefollowing exemptions from control requirements:
a. The design opacity is greaterthan or equal to 151 ms [`950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPa7; or
b. The design capacity Is greaterthan or equal to 75 Ms 1-472 BBL] but less than 151 m31-950 BBL] and stores a liquid with a maximum true vapor pressure greaterthan or equal to 15,0 kPa but less than 27.6 kna7
Storage -''=r:.> not sublet[ to Nisi, el,
40CFR, Part 60, Subpert0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production. Transmission and DIstrtbmion
1. Is this storage vessel hated at a facility in the onshore ail and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this storage vessel constructed,reconstructed, or modified (see definitions 40CFR, 50.2) between August 23, 2011 and September 18, 2015?
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015?
4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
S. Does this garage vessel meet the definition of "storage vessel"' per 60.5430/60.5430a?
6. Is the store evessel sub'ect to and controlled in accordance with re ulrements for store a vessels in 40 CFR Part 50 Sub art Kb or 40CFR. Part 63 Sub art HH7
Go to the next question
Sbrage Tank is not subject NSPS
:NAB
11MI
. .
AI
[Note: If a storage vessel is previously determined to be subject to NSP5 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, It should remain subjectto NSP50000/0000a per
60.5365(e)12)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tans per year]
40 CFR, Part 63, Subpart MALT HH, Oil and Gas Production Facilities
1. Is the storage tank located a[ an oll and natural gas production facility that meets either of the following criteria:
a. Afacliiry that processes, upgrades ar 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))7
2. Is the tank located at a facility that Is majors for HAPs7
3. Does the tank meet the definition of"storage vessel"' In 63.7617
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"' per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 00007
Subpart A, General provisions per 90.764 (a) Table 2
963.766 - Emissions Control Standards
963.773 -Monitoring
§63.774-Recordkeeping
90.775 -Reporting
RACT Review
PACT review Is required if Regulation 7 does not apply AND if the tank Is In the non -attainment area. If the tank meets both criteria, then review RACT requiremerrts.
Disclaimer
*T
44MMI
m�
Continue - You have indicated th
Storage Tank Is not subject NSP5
Go to the next questlon
Storage Tank is not subject NSPS
Continue - You have indicated th
Storage Tank is not subject MAC
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 docianent is not
a rule or regulation, and the analysis it contains may net apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation,
r any other legally binding requirement and is not legally enforceable. /n 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-mandafory language such as'recommend,^'may,^"should,' and'can,"is intended to
describe APCD interpretations and recommendations. Mandatory terminology such as 'muse' and 'required. are intended to descnbe controlling requirements under the terms of the Clean AirAct and Air
Qualify Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
PDC Energy, Inc.
123
9F8B
Gillham 18 Sec HZ
History File Edit Date
10/1/2020
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.6
0.6
0.0
0.0
82.0
1,075.0
0.3
71.8
26.7
0.6
0.6
0.0
0.0
12.0
62.8
0.3
19.7
2.0
Previous Permitted Facilih total
0.4
0.4
0.0
0.0
79.6
1,074.7
0.0
69.8
26.7
0.4
0.4
0.0
0.0
9.6
62.5
0.0
17.7
2.0
001
18WE0042
Twenty (20) 538 bbl fixed roof
condensate storage vessels.
1.3
300.7
2.8
7.5
1.3
15.0
2.8
0.4
Point updated on 10/0'1/2.020. Updating
emissions, DC 10/01/2020.
002
GP07
Condensate loadout
0.4
97.5
0.8
1.7
0.4
10.0
0.8
0.1
No Change
003 '
GP02.CN -
SI RICE GM Vortec 5.7L, 4SRB, 88
HP Site Rated (SNi.
10BX1M105190132):
0.0
0.1
0.1
0.0
Cancellation request received 07/16/2020
004
GP02.CN '.
St RICE GM Vortec 5.7L, 4SRB, 88
HP Site Rated (SN:
10CHMM110080039)
0.0
0,1
0.1
0.0
Cancellation request received 07/16/2020
005
GP02
SI RICE GM Vortec 5.7L, 4SRB, 88
HP Site Rated (SN:
10CHMM503060015)
0.1
0.1
11.8
0.6
9.3
0.1
0.1
0.1
0.9
0.6
1.7
0.1
No Change - engine used for compression
006
GP02.CN
SI RICE GM Vortec5::7L, 4SRB,: 88
HP Site Rated (SN:
1DCHMM410150016)
-
-
0,0
- 0.1
0.1
0.0
Cancellation request. received 06/07/2019'
007
GP02.CN
SI RICE GM Vortec 5.7L, 4SRB, 88
HP Site Rated (SN:
10CHMM503090026)
0.0
0.1
0.1
0.0
Cancellation request received 06/07/2019
008 =
GP02.CN
SI RICE Red River GM 9.8L, 4SRB,.:.
93 HP Site Rated (SEE 9811120028)
0.0
0.0
Cancellation request received 03/22/2018:
Source no longer exists at the facility.
009
GP02.CN
SI RICE Red River GM 9.0L, 4SRB,
136 HP Site Rated (SN: 306654)
0.0
0.1
0.1
0.0
Cancellation request received 07/16/2020
XA
External Combustion Sources
0.2
0.2
2.4
0.1
2.0
0.0
0.2
0.2
2.4
0.1
2.0
0.0
Insignificant Source
XA
Fugitives
0.3
0.0
0.3
0.0
Insignificant Source
XA
Eight (8) 400 bbl and two (2) 210 bbl
fixed roof produced water storage
vessels
0.1
0.0
0.1
0.0
Insignificant Source
FACILITY TOTAL
0.2
0.2
0.0
0.0
16.0
398.9
0.3
14.9
9.3
0.6
0.6
0.0
0.0
5.0
25.8
0.3
7.3
0.6
VOC: Syn Minor (NANSR and OP)
NOx: True Minor (NANSR and OP)
CO: True Minor (PSD and OP)
HAPS: Minor n -Hex 8 Total
HH: Not applicable - area source
7777: Area source
Permitted Facility Total
0.1
0.1
0.0
0.0
13.6
398.8
0.0
12.9
9.3
0.4
0.4
0.0
0.0
2.6
25.6
0.0
5.3
0.6
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.0
0.0
0.0
0.0
-7.0
-36.9
0.0
-12.4
Pubcom required because source is attempting to
obtain a federally enforceable limit on the
potential to emit in order to avoid other
requirements. Modeling not required.
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
26.0
Facility is eligible for GP02 because Nox & VOC <
45 tpy, and CO < 90 tpy.
Project emissions less than 25 tpy
-36.9
Note 2
Page 8 of 9
Printed 12/2/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name PDC Energy. Inc.
County AIRS ID 123
Plant AIRS 10. 9F86
Facility Name Gillham 18 Sec HZ
Emissions - uncontrolled Ilbs per year
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
mylhs's..
Xylenes
n -Hexane
McCH
224 TMP
H2S
TOTAL
PO
Previous FACILITY TOTAL
0.4
0:1
0.1
2.3
2,8
0,1
1,3
19.5
0.1
0.1
0.0
0.0
26,7
001
18WE0042
Twenty (20) 538 bbl fixed roof
condensate storage vessels.
1280.5
1729.2
634
780.2
11172.0
57.9
7.5
002
GP07
Condensate wadcut
343.8
26831
17
003
GP02 CN
SI RICE GM Vortec 5 7L 4SRE 86
HP Site Rated (SN:
108)71 M106190132j-_,
004
GP0'2. CN
S,: RICE GM Vends 571, 4SRB 88
HP Site Rated (SN
10CHMM110080039)
00.
005
GP02
SI RICE GM Vortec 5.7L, 4SRB, 88
HP Site Rated (SN_
10CHMM5030600'15)
006
02 CN
SI: RICE GM Vortec57134SRB, 88'
HP Ste Pater( (SN
104,4714M4101520161
"'
00..
007
GP02.CV
SI RICE GM Vertec.5 7L, 45RE3 88
RP. Sae Rated (SR:
10CF MM5030900261
0.0
008
GP02 C31
SI RICE Reg River GM 98L 1SRS
93 HP S.e Rated (18N 981"120028)
Op.
009
GP02:Crf
36 Red ft ser GM 9 UL 4SRB
125 NP Site Rsted1S_N 306654]
p p
XA
Exte mal Combustion Sources
0,0
XA
Fugitives
._..a
10.,6
t@.!!1
108
12'1
0.0
XA
Eight (8) 400 blot and two (2)210 bbl
fixed roof produced water storage
vessels
4.8
5.&
0.2
'1.6
1 3
0.0
TOTAL (tpy)
0.1
0.0
0.0
0.8
0.9
0.0
0.4
7.1
0.0
0.0
0.0
0.0
9.3
Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text. uncontrolled,emissibns v de minintus
Emissions with controls llhs per year
POINT PERMIT Description
Formaldehyde
AcetamehWle
Acrolein
Benzene
Toluene
Ethylhenzene
Xylenes
n -Hexane
McOH
MA TMP
H2S
' ii
TOTAL
Owl
Previous FACILITY TOTAL
9.4
0.1
0.1
0.2
0.2
0.0
0.1
1.0
0.1
0.0
0.0
0.0
2.0
001
18WE0042
Twenty (20) 538 bbl fixetl roof
condensate storage vessels.
64.0
86.5
92
39.0
5586
2.8
0.4
002
GP07
Condensate loadeut
17.2
149.2
01
003
GP02.CN
SI RICE GM Vertee S. 7L 4SRB, 88
HPSiteRated caN
1UBX1M,0519013?j.
00
.
0e4
GEG2 CR
SI Ric_ GM Vortec 5 IL, 4SRB; 68
h2 SRe Rased (St,
10CHMM1100800391
D.9.
005
GP02
SI RICE GM Verdes 5.71 4SRB, 8
HP Site Rated (SN:
10CHMM503060015)
It c
0
0 1
OY
GPg2:CN ''
SI RICE GM Vortec 5.7L, 4SRB; 88
HP Site Rated (SN
10CHMM410150016t
q 0 ;.
707
O ,Cl
SI RICE GM Mertes 5-7L 4S ,B 98.
HP Ste Rated (SN
10CHMM503090026
0 0
008
Gr 2 C
SI RICE Red River GM 98_ 4SRB
93 HP Site Rated (SIT 9811120028):',
�
0.0
009
GP02.CN
SI RICE Red River GM 9l0., 4SRB
136�HPSite Rated(SNc.306854)
00
XA
Extemal Combustion Sources
0 0
XA
Fugitives
10.8
10,8
105
10.0
12,1
06
XA
Eight (8) 400 bbl and two (2) 210 bbl
fixed roof produced water storage
vessels
4 8
5.6
0 2
1.6
1.3
0.0
TOTAI hey)
0.1
0.0
0.0
0.1
0.1
0.0
0.0
0.4
0.0
0.0
0.0
0.0
0.6
I
18WE0042.CP2
12/2/2020
CDPHE
Condensate Storage Tank(s) APED
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 18WE0042
AIRS ID Number: 123 / 9F8B /001
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Glllham 18 Sec HZ
Site Location: SESE Sec 18 T5N R64W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Jack Starr
Phone Number: (303) 860-5800
E -Mail Address2: Jack.Starr@pdce.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
e COLORADO
1.110
Permit Number: 18WE0042
AIRS ID Number: 123 / 9F8B / 001
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR -
Q MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info £t Notes: Requesting new throughput limit and emissions limits for Construction Permit 18WE0042;
2019 Actual throughput; Emissions calculated using previously approved site -specific emission factors.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Condensate Storage Tanks
TK-1
9/22/2017
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52
Storage tank(s)located at:
✓❑ Exploration £t Production (E&P) site
weeks/year
❑ Midstream or Downstream (non EEO) site
Will this equipment be operated in any NAAQS nonattainment area?
El
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
0
Yes
❑
No
Is the actual annual average hydrocarbon liquid throughput 2 500 bbl/day?
✓❑
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.00430
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
Are you requesting 2 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions 2 6 ton/yr (per storage tank)?
❑✓
Yes
No
■
COLORADO
ge Department of 1,1,w
HadeAb Er:reonmenl
❑ Upward
❑ Horizontal
Permit Number: 18WE0042
AIRS ID Number: 123 / 9F8B / 001
Section 4 - Storage Tank(s) Information
Condensate Throughput:
Actual Annual Amount
(bbl/year)
213,313
Requested Annual Permit Limits
(bbi/year)
255,980
From what year is the actual annum amount? 2019
Average API gravity of sales oil: 51.5 degrees
Tank design: El Fixed roof ❑ Internal floating roof
RVP of sates oil: 11.1
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TK-1
20
10,760
5/2017
9/2017
Wells Serviced by this Storage Tank or Tank Batteryb (E&P Sites On
y)
API Number
Name of Well
Newly Reported Well
05
- 123
- 42865
Gillham 18X-102
❑
05
- 123
- 43902
Gillham 18X-104
IN
05
- 123
- 42864
Gillham 18X-232
■
05
- 123
- 43904
Gillham 18X-234
❑
05
- 123
- 42861
Gillham 18X-332
❑
s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.394325/-104.585206
Q Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack
ID No.
Discharge Height Above
Ground Level (Feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
I
1
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
Interior stack diameter (inches):
Interior stack width (inches):
❑ Upward with obstructing raincap
Interior stack depth (inches):
COLORADO
se aep..,rme cof wbn�
NaatN b M.+.,onmcn,
Permit Number: 18WE0042
AIRS ID Number: 123 / 9F8B r 001
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
❑ Combustion
J
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 9g
Minimum Temperature:
10 x Cimarron 48", 1 x Cimarron 60"
Waste Gas Heat Content:
Constant Pilot Light: Ei Yes ❑ No Pilot Burner Rating:
2,565
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (MP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 23 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
coLoRADO
�wR,M , w�K
xoi�na enn.nmc.�
Permit Number: 18WE0042
AIRS ID Number: 123 / 9F8B / 001
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
V0C
Enclosed Combustor
103%
95%
NOx
CO
HAPs
Enclosed Combustor
100;'0
95%
Other:
From what year is the following reported actual annual emissions data? 2019
Use the following table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(4'-42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissionse
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
2.3491
Ibibbl
ProMax
250.55
12 53
300 66
15 04
NOx
0.1380
Ib/MMBtu
TCEC
N/A
1.12
N/A
133
CO
0.2755
Ib/MM9tu
TCEC
N/A
239
N!A
281
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria
✓❑ Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
(CAS)
Service CAS
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(ibs/year)
Controlled
Emissions$
(lbs/year)
Benzene
71432
00050
lb/bbl
ProMax
1.06710
53.26
Toluene
108883
0 0068
Ibibbl
ProMax
1441 01
72 05
Ethylbenzene
100414
248E-04
lb/bbl
ProMax
5284(DM)
264(DM)
Xylene -
1330207
00030
Ibibbl
ProMax
65012
3251
n -Hexane
110543
0 0436
lb/bbl
ProMax
9,309.84
465.49
2,2,4-Trimethylpentane
540841
223E-04
lb/bbl
ProMax
47.48 (DM)
2.37 (DM)
❑ No
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14.03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
5 i�,'l
Permit Number: 18WE0042
AIRS ID Number: 123 / 9F8B / 001
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Sign
(se—
re of Legally Authorized Person (not a vendor or consultant) Date
Jack Starr
Senior Air Quality Representative
Name (print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303)692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
COLORADO
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml
Company Name:
PDC Energy', Inc.
Source Name:
Gillham 18 Sec HL
Emissions Source AIRS ID':
123 / 9F8B / 001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 43908
Gillham 18X-334
❑
05 - 123 - 42862
Gillham 18Y-202 .
❑
05 - 123 - 43916
Gillham 18Y-214
❑
05 - 123 - 42863
Gillham 18Y-312
❑
05 - 123 - 43914
Gillham 18Y-314
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
Attach this addendum to associated APEN form when needed to report additional wells.
If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
TK-1 Addendum
Hello