HomeMy WebLinkAbout20203828.tiffCOLORADO
Department of Public
Health Et Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
December 14, 2020
Dear Sir or Madam:
RECEIVED
DEC 21 2020
WELD COUNTY
COMMISSIONERS
On December 15, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
PDC Energy, Inc - Klein 19 Sec Pad 1; Josephine 19 Sec HZ. A copy of this public notice and the public
comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive 5., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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V
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc - Klein 19 Sec Pad 1; Josephine 19 Sec HZ - Weld County
Notice Period Begins: December 15, 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: Klein 19 Sec Pad 1; Josephine 19 Sec HZ
Well Production Facility
SWNE quadrant of Section 19, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc. wishes to reduce requested permitted
emission by reducing requested condensate throughput. Specifically to permit 18WE1018, PDC Energy, Inc.
also wishes to reduce requested permitted emission by adjusting VRU downtime to 50 %.
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 drafts of Construction Permits 17WE0552 and
18WE1018 have been filed with the Weld County Clerk's office. A copy of the draft permits 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.Rov/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
1
COLORADO
Department of Public
Health B Environment
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
CONSTRUCTION PERMIT
Permit number: 17WE0552 Issuance: 3
Date issued:
XX/XX/XXXX
Issued to: PDC Energy, Inc.
Facility Name: Klein 19 Sec Pad 1; Josephine 19 Sec HZ
Plant AIRS ID: 123/9F2B
Physical Location: SWNE SEC 19 T5N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-1 (1)
001
Eight (8) 538 barrel fixed roof condensate
storage vessels connected via liquid
manifold.
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 10
COLORADO
Air Pollution Control Division
Department of Public Health Et 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 (1)
001
---
1.2
11.1
25
Point
ote: 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 must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for criteria and hazardous air 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 (1)
001
Enclosed Combustor
VOC and HAP
Page 2 of 10
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
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
Facility
Equipment ID
AIRS
Point
Process
Process Parameter
Annual Limit
TK-1 (1)
001
01
Condensate Throughput
218,422 barrels
02
Combustion of pilot
light gas
1.0 MMscf
The owner or operator must monitor monthly process rates based on the calendar month.
Compliancewith 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 I I I. 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
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Pubttc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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%.
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 £t MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (0&tM) 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 OaM`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:
Page 4 of 10
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 any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
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
Page 5 of 10
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
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
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 3
This Issuance
Issued to PDC Energy, Inc. Operator reduced
permitted emissions by reducing requested
condensate throughput.
Issuance 2
August 23, 2019
Modification to reduce throughput due to
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Publtc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
production decline. Tank count and volume
decreased.
Issuance 1
December 13, 2017
Issued to PDC Energy, Inc.
Page 7 of 10
le.
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
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, fottowed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
N
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
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(Ib/yr)
001
Benzene
71432
1269
63
Toluene
108883
1333
67
Ethylbenzene
100414
44
2
Xylenes
1330207
559
28
n -Hexane
110543
9231
462
2,2,4-
Trimethylpentane
540841
85
4
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
1.068x10-2
1.068x10-2
TNRCC and Promax
CO
2.133x10-2
2.133x10"2
TNRCC and Promax
VOC
2.0326
1.0163x10-'
Promax
Page 8 of 10
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
71432
Benzene
5.810x10-3
2.905x10-4
Promax
108883
Toluene
6.105x10-3
3.053x10-4
Promax
1330207
Xylene
2.557x10"3
1.279x10-4
Promax
110543
n -Hexane
4.226x10"z
2.113x10-3
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 Klein 19P-202 well
on 05/11/2017. 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 2339.0 Btu/scf, molecular weight of 41.7 lb/lbmole,
a standard molar volume of 379.41 scf/lb-mole, and a VOC mot% of 55.8 %. 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
Table 13.5-2
VOC
6.1
AP -42 Chapter 14
Table 1.4-2
CO
352.2
AP -42 Chapter 13.5
Table 13.5-2
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 0.31 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
emissionfactor 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 seven (7) combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 109.2 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
Page 9 of 10
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
Operating Permit
Synthetic Minor Source of: VOC, NOx, and n -Hexane. True Minor
Source of CO.
PSD
True Minor Source of: CO.
NANSR
Synthetic Minor Source of: VOC and NOx.
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
63.60O-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
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
Diego Chimendes
434237
7/31/2020
11/23/2020
Section 01 - Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: 9F2B
Facility Name: Klein 19 Sec Pad 1; Josephine 19 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? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
SWNE quadrant of Section 19, 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(1)
Yes
17WE0552
3
Yes
Permit
Modification
Quadrant
Section
Township
Range
SWNE
19
SN
64
Section 03 - Description of Project
PDC Energy, Inc. (PDC) submitted an application requesting modification of permit 17WE0552. PDC wishes to reduce requested permitted emissions by reducing
requested condensate throughput.
This point source is APEN-required because uncontrolled VOC 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 11.6.3.) Point source is permit -required because uncontrolled facility -wide VOC emissions are greater than 2 tpy.
(Regulation 3 Part B Section II.D.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 the source in order to
avoid other requirements. (Regulation 3 Part B Sections III.C.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 Requiired? Yes,
If yes, why? .Requesting Synthetic Minor Permit
Section OS - 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.
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: SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
_
NOx _
No
Yes
CO
_
J
✓
No
VOC
_
P
PM2.5
_
../
✓
PM10
_
TSP HAPs
_
J
Colorado Air Permitting Project
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title VOperating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx CO VOC PM2.5 PM1D TSP HAPs
❑ ❑
Storage Tan (s) Emissions (n;sentory
Section 01 -Administrative Information
Facility Al Rs ID:
123
County
9F26
Plant
001
Point
Section 02 - Equipment Description Details
Storage Tank Liquid �; Condensate
Detailed Emissions Unit Eight (8) 538 barrel fixed roof liquid manifold storage vessels used to store condensate,
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control Efficiency %:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Actual Throughput =
Requested Permit Limit Throughput=
Six (6) Cimarron 48 & one (1) Cimarron 60" enclosed combustors.
95.0
218,422.0 Barrels (bbl) per year
218,422.0 Barrels (bbl) per year
Requested Monthly Throughput= 18550.9 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
produced=
Molecular Weight=
VOC cool%=
Molar Volume =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
218,422.0 Barrels (bbl) per year
2339.0 Btu/scf
scf/bbl
41.7 Ib/Ibmol
55.8%
379.4 scf/Ibmol
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
16,909.8 MMBTU per year
16,909.8 MMBTU per year
16,909.8 MMBTU per year
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
109.2 scfh
1]36 Btu/scf
1.0 MMscf/yr
1086.7 MMBTU/yr
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
. 2.0325
1.0163E-01
Slte Specific E.F. (includoir
Site Specific E.F.(incl.!e-*'�
Site Specific S.F.(includes'-�
Site Specific E.F. (includes..'-
Site Specific E.F. (include,
Site Specific E:F.(includes,--
Site Specific E.F.(includs
e
Benzene
5.810E-03
2.905E-04
Toluene
6.105E-03
3.053E-04
Ethylbenzene
2,004E-04
1.002E-05
Xylene
2.557E-03
1.279E-04
n -Hexane
4.226E-02
2.113E-03
224 TMP
3.873E-04
1.936E-05
Pollutant
• Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
5.768E-04
AP -42 Table 1.42 (PM10/PM.2.5)
AP -42 Table 14-2(PM30/PM25) ,
Other -Expl
TNRCC Flare Emissions Guidance INOxj
TNRCC Flare Emissions Guidance t•CCri'
PM2.5
0.0075
5.768E-04
SOx
0.0006
4.554E-05
NOx
..0.1380
1.068E-02
CO
0.2755
2.133E-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
.._
AP -42 Table 1.42(PMIOJPM.$:?-.
AP -42 Table 1.4-2(P U •,
AP -42 Table 1.42~ e
AP-42Chapter13,,.' - -
AP -42 Table 1.4-2 .s
AP -42 Chapter 13Si du
PM2.5
0.0075
8.5
SOx
0.0006
0.7
NOx
0.0680
77.2
VOC
0.0054
6.1
CO
03100
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
(tons/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
11.4
0.1
0.1
0.1
0.1
0.1
11.4
0.0
0.0
0.0
0.0
0.0
0.9
1.2
1.2
1.2
1.2
1.2
204.5
222.0
222.0
11.1
222.0
11.1
1885.8
2.5
2.5
2.5
2.5
2.5
424.3
1
3 of
KAPA\2017\17WE0552.CP3
Storage Tank(s) Emissions Inventory
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(Ibs/year)
(Ibs/yearl (I,./year)
(Ibs/year) (Ibs/year)
Benzene
1269.0
1269.0
63.5
1269
63
Toluene
-.. 1333.5
1333.5
66.7
1333
67
Ethylbenzene
43.8
43.8
2.2
44
2
%ylene
558.6
558.6
27.9
559
28
n -Hexane
9231.4
9231.4
461.6
9231
462
224 TMP
84.6
84.6
4.2
85
4
4 of 9 KAPA\2017\17WE0552.CP3
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit -
Regulation 7, Part D,Section I.C, D, E, F -
Storage tank is subject to Regulation 7, Part D, Section I.C-F
Regulation 7, Part D,Section l.G, C
Storage Tank is. not subject to Regulation 7, Section l.G
Regulation 7, Part D,Section 11.8, C.1, C.3
Storage tank is subject to Regulation 7, Part D, Section II, B, C.1.& C.3
Regulation 7, Part D,Section 11.02
Storage tank is subject to Regulation. 7,. Part D; Section ll.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.C.4.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 8, 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 tpy?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop asite specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
Ryes and if there are flash emissions, are the emissions factors -based on a pressurized liquid sample drawn at the facility being
permitted (forproduced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? 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 he 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 guideline
Does the company request a control 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. Ste 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 Klein 19u-
202well. This well isone of the eight (8)wails whose liquids are directed to this facility and there were no significant changs to the facility since the development of the emissions factors. As a result, the permit will
t require initial testing in order to obtain a new site specific sarn le. it should be noted that the sample includes sampleprobe temperature and pressure in conjunction With gauge pressure and temperature.
dary Emissions Calculations:
2.1 Operator used the following equation to calculate the annual heat input
-,.welt (MMBtu/yr)= [Uncontrolled VOC(ton/yr)]>[2000(ib/ton}] MW(lb/lbmol)+[37441(sc//Ib.71)]=[t/VOCmot %]=[Heat Content (Bt iscr)]s-j1M'�9Btu/(1000, 000 Bb 11.:'..
The values used m the; equation were obtained from a PtoMax simulation used to calculate emissions and develop emission facto-.. The values used are as follow, ( ) Molecular w 'gnt: 41.61bjlb cool, hit VO:. mo; %-
55.43%, MP Heat Content, 23332 Stu/scf.
3. Pilot Light Emissions Calculations, Operator assumed pilot fuel to have the same conditions of field gas which is cons stentwith the plant design provide by operator. The permit w ii not containinitial or periodic
-j opacity testing for the enclosed combustor(s)because the O&M plan. approved for thisource requires weekly visible emissionsobsevations of the enclosed combustor(s). Athroughput limit is included in the permit
fw pilot combustion. Emission factors and calculation methodsfor pilot light combustion emissions are also included in thenotes to, permit holder. This tnformationis included in the permit because pilot light
emissions contribute to the over all emasion front source. Additionally it is important to include this information becrose throughput tracking and emisson calculation methods are different than those used to
mate emissions based on the condensate throughput. This. clarity is important for accurately quantifying actual .mt.sionsat this facility.
U
if certification received on 0`0/05/2618 and approved on 06/07/2018.
AIRS Point #
001
Process #
01
SCC Code
Fixed Roofi,'fank;
.4** afhft),giffAip
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
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
5Ox #REFI 0 lb/1,000 gallons Condensate throughput
NOx 0.26 0 lb/1,000 gallons Condensate throughput
VOC 48.40 95 lb/1,000 gallons Condensate throughput
CO 0.54 0 lb/1,000 gallons Condensate throughput
Benzene 0.14 95 lb/1,000 gallons Condensate throughput
Toluene 0.15 95 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons Condensate throughput
Xylene 0.06 95 lb/1,000 gallons Condensate throughput
n -Hexane 1.01 95 lb/1,000 gallons Condensate throughput
224 TMP 0.01 95 lb/1,000 gallons Condensate throughput
5 of
KAPA\2017\17W E0552.CP3
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado R. latlo 3P its Aand B APEN andPermit Requirements
1cc- _.,-. -. w.v
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from thh individual source greater than 2 TPY (Regulation 3, Part A, Section ll.D,1.a)?
2 Is the uc[ d (service date) pto 12/30/2002.d not modifiedarter 12/31/2002 (See PS Memo 0501 Definitions 1.12 and114and 5 2 for additional guidance an grandfather applicability)?
3 A tt lfcility uncontrolledVOC emissions gre.erthan STPV NOx greater than 10TPY or CO emissions greater than lO TPY (Regulation 3, Part B, Section ll.D3)7
!Source
u.tio APEN Go to
G t ert q res an
Source Requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater thaml TPY (Regulation 3, Part A,Sertion Bata)?
2. Is the construction date (service date) prior to 12/30/2002 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 Are total facility uncontrolled VOC emissions greaterthan 2 TPY. NOx greater than 5 TPY or CO emissions greater than lOTPY(Regulrtlon 3, Part B, Section ll.D.2)7
ISa, . , __e -.
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/ma ea(Regulation 7, Part 0, Section l.A.1)7
2. Is this storage tank located at ail and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are looted at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A.1)7
3. Is thk storage tank located at a natural gas processing plant (Regulation 7, Part D, Section 1.G)?
4. Does this storage tank contain condensate?
5. Does this storage tank exhibit "Flash" (e.g. storing non-rtabillzed liquids) emissions (Regulation J, part D,Section Lel)?
6. Are uncontrolled actual emissions of this stora etank e ual to or reater than 2 ions per year VOC (Regulation 7, Part D, Settionl.D3a(ii )?
PartD, Section I.C.1 —General Requirements for Air Pollution Control Equipment— Prevention of Leakage
Part D, Section I.O2— Emission Estimation Procedures
Part D, Section 1.0— Emissions Control Requirements
Part D, Section LE —Monitoring
Part D, Section kr— Recordkeeping and Reporting
Rog:id:tun J. Secy.-7T G
Part D, Section I.G.2- Emissions Control Requirements
Part 0, Section I.C.I.a and b —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Colorado Regulation 7, Part D, Section!'
1. Is this storage tank located at a transmission/storage facility?
2. Is this storage tank" located at an oil and gas exploration and production operation, well production facility',natural gas compressor station or natural gas processing plane(Regulation 7, Part D,5ectionll.C)?
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section ll.A.2o)?
4. Are uncontrolled actual emissions of this storagetank equal to or greaterthan 2 tons per year VOC(Regulation J, Part D, Sertionll.Clc)?
I 'Crag
F
Nc'
Source Requires an APEN. Go to
Go to next question
Source Requires permit
Continue - You have Indicated th
Continue -You have Indicated th
Storage Tank is not subject to Rc
Continue - You have indicatedth
Go to the next question -You ha
Go to the nexrt question
Source Is subject to parts of Reg
Part D, Section11.0 Provisions for Alr Pollution Control Equipment and Prevention of Emissions
Part D, Section 11.C.1- Emissions Control and Monitoring Provisions
Part D, Section II.C.3 - Recordkeeping Requirements
5 D the storag k my "stabilized Iiqud (Reg7, Part 0, Section ll.C2.b)? d}pa, I5Durca's subject to all provision:
- I K .<-.: Svcc4.n 1�. 2
Part D, Section llC2 Capture dMonitoring frStorage T its fitted with Air Pollution Control Equipment
Is the controlled storage tank located a[ welt production facility, natural gas compressor staton, or nature(g processing plant constructed on or after May 1,2020 or Bloated at a faclkythat was modified on or after May 1, 2020,s h 'g1 'P
6 h additional controlled storaget ctd[ 'Wanticipatedncreasen throughput of hydrocarbon liquids or eroduad water (Regulation 7, Part D, Section lLC4a()7 at'efu, _ °]Storage Tanks not subject to Re
Thift ifot
Is the trolled storage tank lt d at a wellproduction facility, t l gas compressorstation, or natural gas processing plant constructed on or afterlanuary 1, 2021 or located at a faclitty that was modified on or afterlanuary 1, >
J 2021, such that an additionalcontrolled storage vesselI t tt dtanticipated Increase in throughput of hydrocarbon liquids or produced water (Regulation 7 Part D, Section ll C4a.(I)?
ISzomrtifiWiL k m K.K.Irtjw,„r., S.0-0-, _.
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 (m3) (-472 BBIs] (40 CFR 60.1106(a))?
2. Doesthe storage vessel meet the following exemption in 60.1316(d)(4)7
a. Does the vessel has a design capacity less than or equal to 1,589.874 ma[ -l0,000 BBL] used for petroleum') or condensate=stored,processed, or treated prior. custody transfer' as defined in 60.1116?
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984(40CFR 60.3106(a))7
4. Does the tank meet the definition of"storage vessel"' in 60.11lb? -
5. Does the storage vessel store a"volatile organic liquid(VOL)"sas defined in 60.1116?
6. Does the storage v sel meet any one of the following additional exemptions.
a. Is the storage vessel a pressure vesseltlesigned to operate in excess of 204.9 kPa]'29.7 psi] and without emissions to theatmosphere(60.110b(d)(2))?;or
b. The design capacity is greater than or equal to 151 ms (-950 BBL) and stares a liquid with a maximum we vapor pressure less than 35 kna (60.1106(b))?; or
c. The design capacity is greater than or equal to 75 Ms [-472 BBL] but less than 151 ms [`350 BBB] and stores a liquid with `maximum true vapor pressure` less than 15.0 kPa(60.11ob(b))?
7. Does the storage tank meet either one of thefollowing exemptionsfrom control requirements:
a. The design capacity is greater than or equal to 151 ms (`950 BBL] and stares a liquid with a maximum tole vapor pressurwgreater than or equal to 3.5 kPa but less than 5.2 NM?, or
b. The design p ty is greater than or equal to 75 Ms( -472 BBL] but less than 151 ma[`950 Bat] and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa?
Go to the next question
Storage Tank is not subject N5PE
t
NOW
40 CFR, Part 60, Subpart 0000/0000a. Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Isthis storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processingsegneni or natural gas transmission and storage segment of the industry?
2. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Was this storage vessel constructed,reconstructed, or modgied(see definitions 40 CFR, 60.2) after September 18, 2915?
4. Are potential VOC emissionssfrom the individual storage vessel greater than or equalto 6 tons per year?
5. Does this storage vessel meet the definition of )(storage vessel"' per 60:5430/60.5430a?
6 Is the storagev vessel bj ctt dcontrolled In accordance with re mrements forst°. evessels n40 CFR Part 6o Sub art Kb or 40CFR Part 63 Sub art HH7
I5rmpq tank NB,00i).a
[Note: If a sorage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tans per year VOC onthe applicability determination date, It should remain subjectto NSP5 0000/0000a per
60.5365(e)(2)/60.5365a(e)(2] even if potential VOC emissions drop below 6 tons per year]
48 CFR. Part 63, Subpart MACT HH, 011 and Gas Production Facilities
1. Is. the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. Afacility that processes, upgrades or stores hydrocarbon liquids'(63.76o(a)(2)); OR
b. Afacllity 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 use'(63.760(a)(3))?
2. Is the tank located at a facility that is majors for HAPs?
3. Does the tank meet the definition of"sorage vessel"4In 63.761?
4. Does the tank meet the definition of"storage vessel with the potentialfar flash emissions"' per 63.761?
5. Is the tank subject. control requirements under 40 CFR Part -60, Subpart Kb or Subpart 00007
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 -Emissions Control Standards
§63,773 -Monitoring
§63.774-Recordkeeping
§63.775 -Reporting
RAC' 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 bath criteria then review RACT requirements.
Disclaimer
'ts]g'9s5,"Sk
Continue - You have indicated th
Storage Tank is not subject NSPF
Go to the next question
Storage Tank is not subject NSP5
ominue- You haveindiated th
torage 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 document is not
a rule -or regulation, and the analysis it containsmay not apply to a padicular situation based upon the individual facts and circumstances. Thisdocument does not change or substitute for any law, regulation,
r 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
desc'e APCO interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe 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
PDC Energy, Inc.
123
9F2B
Facility Name
Klein 19 Sec Pad 1; Josephine 19 Sec HZ
History File Edit Date
Ozone Status
12/14/2020
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
AIRS
PERMIT
Description PM10
ID VOC HAPs
PM2.5
H2S
SO2
NOx
VOC
Fug
CO
Total
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL 1.0
1.0
0.0
0.0
103.5
1864.9
0.5
95.1
49.3
1.0
1.0
0.0
0.0
18.5
80.0
0.5
28.7
3.0
Previous Permitted Facility total 0.5
0.5
0.0
0.0
97.4
1864.3
0.0
89.9
49.1
0.5
0.5
0.0
0.0
12.4
79.3
0.0
23.6
2.9
001
17WE0552
Sixteen (16) 538 bbl fixed roof condensate
stora a vessels
1.2
222.0
2.5
6.3
1.2
11.1
2.5
0.3
Updated 00 1117 312 0 2 0, Changed emissiruls lirniis.
002 :
GP05,CN
Six (6) 400 bbl and (2) 210 bbl fixed
0
0 5;-
-
...0
Below Thresholds
003
GP07
Condensate Truck Loadout
0
0.6
10 0
1 3
0.1
No Change
004
GP02.CN
RICE - GM Vortec 5.7L 4SRB 88HP (SN
0 0
10.0
005
GP02CN
RICE- GM Vortec 5.7L 4SRB: 88HP (SN
00
0.0
006
GP02 CN
RICE GM Vortec 5,7L 4SRB 88HP (SN
0.0
0 0
007
GP02 CN
RICE -Red River GM 9.0L 4SRB 136HP
0.0
0.0
008
GP02
RICE GM Vortec 5:7L 4SRB 88HP (SN
0.0
0.0
Cancelled 8/2/2019; No LongerC-xists
009
GP02
SI RICE GM Vortec 5.7L 4SRB, 88 HP,
-
0.0...
0.0
010
18WE1013.XP
SI RICE rCummins :G5.9, 4SRB; 47 HP (site
`-
0.0
0.0
Cancelled 7/12/2019 No Longer Exists
011 -
18WE1014 XP
SI RICECummins: G5.9, 4SRB, 47 HP (site
0.0
0.0
Cancelled 7/12/2019 No Longer Exists
012
18WE1015 XP
SI RICE Cummins G5.9, 4SRB, 47 PIP (site
0 0
0 0
5 9
1 0
3 2
0.1
0.0
0 0
0 5
0 3
0 9
0 1
No Change
013 :
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138 f
0.0
- 0:0 :.
Cancelled 7/31/2019 No Longer Exists
014
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138
HP (site rated) SN: G6X07440
0.1
0.1
17.9
1.0
17.9
0.4
0.1
0.1
1.4
1.0
2.7
0.4
_
No Change
015
GP02
SI RICE Caterpillar G3306NA, 4SR8 138
0.0 '
0:0
Cancelled 7/31/2019 No Longer Exists
016
GP02
SI RICE: CaterpillarG3406TA, 4SRB, 276
0 0
„ . „ .
0.0
Cancelled 7/11/201.9 No Longer. Exists
017
18WE1018
One (1) 300 bbl and twenty (20) 538 bbl
fixed roof condensate storage vessels
1.1
473.6
24
12.4
1 1
11.9
2 4
0.3
Updated on '11/23/2020 t 1 all,_ rm
pc 11;03;2070
018
GP02 CN
SI RICE:.Rad RIVerIGM 9.0L„4SRB 36 HP
:
00 r.
r.' 0.0
Cancellation received 07/31/2020.
019
GP02
GM Vortec 5.7L 88hp RICE
0.1
0.1
11.9
0.6
9.3
O.
0.1
O.
0.9
0.6
1.7
0.1
No Change
020
GP02
GM Vortec 5 7L 88hp RICE
0 1
0.1
11 9
0.6
9.3
0.1
0.1
0.1
0.9
0.6
1.7
0.1
No Change
021
GP02
RICE 143 Hp
:
0.0
0',0
Cancelled 9/26/2019, No Longer.Exists
022
GP02
RICE 92 Hp
11 9
0 6
9 3
0 1
0.9
0.6
1 7
0.1
No Change
023
GP02 CN :.
MOW GM 9 OL 136 hp (site) SN: 3189
-
0.0
0 0
Cancellation received 07/31/2020
.XA
External Combustion Sources
0.5
0.5
6.1
0.2
5.1
0.0 0.5
0.5
6.1
0.2
5.1
0.0
Insignificant Source
.XA
Fugitives
0.4
0.0
_
0.4
0.0
Insignificant Source
.XA
Produced Water Tanks TK-2 (1)
0.2
0.0
0.2
0.0
Insignificant Source
XA
Produced Water Tanks TK-2 (2)
0.0
0.0
Insignificant Source
FACILITY TOTAL
0.8
0.8
0.0
0.0
68.5
856.7
0.4
60.3
22.2
0.8
0.8
0.0
0.0
13.6
36.9
0.4
19.9
1.6
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: True Minor (OP and PSD)
HAPS: Syn Minor n -Hex
HH: Not applicable - Area source
7777: Area Source
Permitted Facility Total
0.3
0.3
0.0
0.0
56.6
854.8
0.0
51.9
22.0
0.3
0.3
0.0
0.0
7.0
35.8
0.0
13.9
1.4
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
-0.2
-0.2
0.0
0.0
-5.4
-43.6
0.0
-9.7
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.
Total VOC Facility Emissions (point and fugitive)
37.3
Facility is eligible for GP02 because CO< 90 tpy &
NoxNOC< 45 toy.
(A) Change in Total Permitted VOC emissions (point and fugitive)
-43.6
Project emissions less than 25 tpy
Page 8 of 9
Printed 12/14/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY- HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
PDC Energy, Inc.
123
9F2B
Klein 19 Sac Pad 1; Joaaphine 18 Sec HZ
Fm
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL
tw1
Previously permitted emissions
0.7
0.1
0.1
4.4
4.9
0.2
1.9
38.7
0.1
0.2
49.3
001
17WE0552
Sateen (16) 538 bbl fixed roof condensate
1269 0
1333.5
•9.3.8
558.6
9231.5
84.6
6.3
002
GP05.CN
Siz (6) 400 bbl and two (2) 210 bbl foxed roof
3.2 .0
414
14
17.1
29 0
0.1
003
GP07
Condensate Truck Loadout
551.4
4784,7
2,7
004
GP02.CN
RICE -GM Vortec 5.744SRB 88HP(SN:
0 ,.
005
GP02.CN
RICE- GM Vortec 5744SRB 88HP(SNi
-
0,0
006
GP02.CN
RICE -GM Vortec 5.7L 4SRB SBHP(SNi
-
0:0
007
GP02.CN
RICE - Red River GM 9.04 4SRB 136HP
0.0
008
GP02
RICE- GM Vortec 5.7L 4SRB 88HP(SN:
0.0
009
GP02
SI RICE GM Vortec 5.7L, 4SRB, 88 HP, SN:
0.0
010
18WE1013,XP
SI RICE Cummins G5.9, 4SRB, 47 HP (site
0.0
011
18WE1014.XP
SI RICE Cummins G5.9, 4SRB, 47 HP (site
0.0
012
18WE1015.XP
SI RICE Cummins G5.9, 4SRB, 47 HP (site
7, G
10.6
i '16
0,1
013
GP02
SI RICE Caterpillar G3306NA, 4SRB; 138
0,0
014
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138
7186
_.,
_�.,
1,
„9
04
015
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138
-
-
0.0
016
GP02
SI RICE Caterpillar G3406TA, 4SRB, 276
0.0
017
18WE1018
One (1) 300 bbl and twenty (20) 538 bbl
2033.1
2672.3
i.(i
984.4
18904.0
67 3
12.4
018
GP02.CN
SI RICE Red River GM 9.0L, 4SRB, 136 HP
0.0
019
GP02
GM Vortec 5.7L 88hp RICE
34.0
1,,.G
.-
0.1
020
GP02
GM Vortec 5.7L 88hp RICE
ID) 0
I =.
„ _
_0.0
0.1
021
GP02
RICE 143 Hp
0.0
022
GP02
RICE 92 Hp
::'ii/
:-'0.%
2,i'I
,..
?:1.1
0.1
023
GP02.CN
MDW GM 9.0L 136'hp (site) SN. 318915
-_0 0
.XA
External Combustion Sources
p.0
.XA
Fugitives
i8 o
re )
c.'I
1.8:1
21.1
0.0
.XA
Produced Water Tanks TK-2(1)
1'17
1 i
0 -
6 2
10.6
0.0
XA
Produced Water Tanks TK-2 (2)
3.8
4.9
0.1
1 6
1.4
0.0
TOTAL (tpy)
0.5
0.0
0.0
2.0
2.1
0.1
0.8
16.5
0.0
0.1
22,2
E
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL
UpY)
Previously permitted emissions
0.7
0.1
0.1
0.3
0.2
0.0
0.1
- 1.5
0.1
' 0.0
3.0
001
17WE0552
Sateen (16) 538 bbl fixed roof condensate
63.5
66.7
27.9
461.6
0.3
002
GP05,CN
Sec (6) 400 bbl and Nye (2) 210 bbl faed roof
32 0
41 4
14
17 1
29 0
0.1
003
GP07
Condensate Truck Loadout
27.6
239.2
0.1
004
GP02.CN
RICE- GM Vortec 5.74 4SRB 88HP(SNt
-
0.0
005
GP02.CN
RICE:- GM Vortec 5.74 4SRB 88HP.(SN;
0.0
006
GP02.CN
RICE - GM Vortec 5.74 4SRB 88HP (SN:
-
0.0
007
GP02.CN
RICE- Red River GM 9.04 4SRB 136HP
00
008
GP02
RICE- GM Vortec 5.7L 4SRB 88HP(SN:
0.0
009
GP02
SI RICE GM Vortec 5.74, 4SRB, 88 HP, SR
0.0
010
18WE1013.XP
SI RICE Cummins G5.9, 4SRB, 47 HP (site
0.0
011
18WE1014.XP
SI RICE Cummins G5.9, 4SRB, 47 HP (site
0.0
012
18WE1015.XP
SI RICE Cummins G5.9, 4SRB, 47 HP (site
/ e,lo
c
ill G
(1.0
11.6
0.1
013
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138
0 p
014
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138
718.6
-
_-4,
1, ,8
, _-
0.4
015
GP02
SI RICE Caterpillar G3306NA, 4SRB, 138
0.0
016
GP02 -
SI RICE Caterpillar G3406TA, 4SRB', 276.
-
. 0,0
017
18WE7018
One (1) 300 bbl and twenty (20) 538 bbl
50.8
66,8
9
24.6
472.6
,?.;+
0.3
018
GPOZCN '
SI RICE Red Rivet GM SOL, 4SRB, 136 HP
-
---
_
0.0
019
GP02
GM Vortec 6.7L 88hp RICE
-
9 0
18.0
11.0
0.1
020
GP02
GM Vane°5.7L 88hp RICE
., ,.
190
..,.il
1I.0
01
021
GP02.
RICE 143 Hp
0.0
022
GP02
RICE 92 Hp
.4 .7
';1i.7
:i0-1
2,1 ,
34
0.1
023
GP02.CN'
MDW GM 9.0L 196 hp (site) SN 318915 ..
..
0.0
.XA
External Combustion Sources
0.0
.XA
Fugitives
18.6
18.7
18.1
18.2
21,1
00
.XA
Produced Water Tanks TK-2(1)
11.7
15.1
0.5
G 2
10.6
0,0
XA
Produced Water Tanks TK-2(2)
3.8
4.9
0.'I
1.c',
1A
0.0
TOTAL(tpy)
0.5
0.0
0.0
0.1
0.1
0.0
0.1
0.6
0.0
0.0
1.6
9
17WE0552.CP3
12/14/2020
COLORADO
Air Pollution Control Division
Department of Public Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
18WE1018
xx/xx/xxxx
PDC Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 2
Klein 19 Sec Pad 1; Josephine 19 Sec HZ
123/9F26
SWNE SEC 19 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 (2)
017
One (1) 300 bbl and
fourteen (14) 538 bbl fixed
roof storage vessels used to
store condensate. Vessels
are connected via liquid
manifold.
Emissions from the storage vessels are
routed to a sates pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s). The VRU has a maximum of
50% annual downtime.
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 operators 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
Page 1 of 10
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
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 I I I. 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
NO,
VOC
CO
TK-1 (2)
017
---
1.1
11.9
2.4
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 criteria and hazardous air 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
AIRS
Control Device
Pollutants
Equipment ID
Point
Controlled
Page 2 of 10
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
Emissions from the storage vessels are routed
to a sales pipeline through the use of a vapor
TK-1 (2)
017
recovery unit (VRU). During VRU downtime,
emissions are routed to enclosed
combustor(s). The VRU has a maximum of 50
annual downtime.
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
Facility
Equipment ID
AIRS
Point
Process
Process Parameter
Annual Limit
TK-1
001
01
Total Condensate
Throughput
326,630 barrels
Condensate throughput
during VRU downtime.
163,315 barrels
02
Combustion of pilot
light gas
1.6 MMscf
The owner or, operator shall 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
8. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the condensate storage vessels are routed to the
enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total condensate
throughput volume and total condensate throughput volume during VRU downtime shall be
recorded on a monthly basis. The owner or operator must use monthly VRU downtime records,
monthly condensate throughput volume records, and the calculation methods established in
the Notes to Permit Holder to demonstrate compliance with the process and emission limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. 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)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
Page 3 of 10
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
11. 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)
12. 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.
13. 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%.
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.
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, Part D, Section II.C.2.
15. 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
16. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (oam) 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.)
Page 4 of 10
a '4
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
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal. requirement.
ADDITIONAL REQUIREMENTS
19. All previous versions of this permit are cancelled upon issuance of this permit.
20. 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
For volatile organic compounds (VOC) and nitrogen oxides sources (NO),) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
21. 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
Page 5 of 10
„„,
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
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
22. 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.
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
28. 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.
Page 6 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Enwonment
Dedicated to protecting and improving the health and environment of the people of Colorado
By: DRAFT
Diego Chimendes
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
August 23, 2019
Issued to PDC Energy, Inc.
Issuance 2
This Issuance
Issued to PDC Energy, Inc. Operator
reduced permitted emissions by:
• Reducing requested condensate
throughput.
• Decreasing maximum VRU downtime
to 50.0 %.
Page 7 of 10
atze
COLORADO
Air Pollution Control Division
Department of Public Health Et 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/agcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
N
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
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
2033
51
Toluene
108883
2672
67
Ethylbenzene
100414
75
2
Xylenes
1330207
984
25
n -Hexane
110543
18904
473
2,2,4-
Trimethylpentane
540841
88
2
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
6.324x10-3
6.324x1O3
TNRCC and Promax
CO
1.263x10-2
1.263x10-2
TNRCC and Promax
Page 8 of 10
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
VOC
2.9001
7.2503x10-2
Promax - Site
specific
71432
Benzene
6.225x10-3
1.556x10-4
Promax - Site
specific
108883
Toluene
8.181x10-3
2.045x10-4
Promax - Site
specific
1330207
Xylene
3.014x10-3
7.534x10-5
Promax - Site
specific
110543
n -Hexane
5.788x10-2
1.447x10-3
Promax - Site
specific
Note:
The controlled emissions factors for this point are based on a control efficiency of 100% when emissions are
routed to the VRU and a control efficiency of 95% when emissions are routed to the enclosed combustor(s)
during VRU downtime. 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 Josephine 19M-234 well on 09/07/2018. 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 2540.6 Btu/scf, molecular weight of 45.3 lb/lbmole, a standard molar volume of 379.41 scf/lb-
mole, and a VOC mot% of 67.3 %. 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 0.31 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 twelve (12) combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 187.2 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
Page 9 of 10
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
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, NOx, and n -Hexane. True Minor
Source of CO.
PSD
True Minor Source of: CO.
NANSR
Synthetic Minor Source of: VOC and NOx.
MACT H
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.Rov/
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 XXXXXX
Page 10 of 10
Colorado Afr g Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package #:
Received Date:
Review Start Date:
DiegoCtimendes
434237
7/31/2020
11/23/2020
Section 01- Facility Information
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name:
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? Yes,
If yes, for what pollutant? Ozone (NOx & VOC) ;
POC;Energy, Inc.
17.3
9F28
Klein 19 Sec Pad 1; Josephine 19 Sec HZ
SWNE quadrant of Section 19, Township 5N, Range 64W
Weld County
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
SWNE
19
5N `
64'!-
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
017
-. , Storage Tank
TK-1 (2)
Yes
18WE1018
2
Yes
Permit
Modification
Section 03 - Description of Project
PDC Energy, Inc. (PDC) submitted an application requesting modification of permit 18WE1018. PDC wishes to reduce requested permitted emission by reducing
requested condensate throughput and adjusting VRU downtime to 50 %. This facility utilizes two (2) different kinds of emission control devices for the condensate
storage tanks; Enclosed Combustors and Vapor Recovery Units (VRUs). Tank vapors are routed to e VRU which compresses the gas before it is sold into a pipeline. Any
vapors not recaptured by the VRU are sent to the Enclosed Combustors.
This point source is APEN-required because uncontrolled VOC emis
greater than 250 tpy. (Regulation 3 Part A Section II -B.3.) Point source
(Regulation 3 Part BSection ILD.2.).
This point source is subject to public comments because source is at
avoid other requirements. (Regulation 3 Part 6 Sections
Point source is not subject to
biers=r
are greater than 1 tpy and uncontrolled emissions of at leastone non -
permit -required because uncontrolled facility -wide VOC emissions are
ptfng to obtain a federaln enforceable limit on the potential to emit of the source in order t
pi 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? IYes
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.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC
Prevention of Significant Deterioration (PSD) _ _
Title V Operating Permits (OP) J J
PM2.5 PM10 TSP HAPs
_ _
El
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
Colorado Air Permuting Project
L
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑
Storage Tank=s; Emissions Inventory
Section 01 -Administrative Information
'Facility AIRS ID:
123
County
9F28
Plant
017
Point
Section 02 - Equipment Description Details
Storage Tank Liquid
Wni�ensate �'� �`
Detailed Emissions Unit One (1) 300 bbl and fourteen :(14) 538 bbl fixed roof condensate storage vessels connected via liquid manifold.
Description: -
Emission Control Device
Description:
Control Efficiency of VRU
Control Efficiency of ECD
Requested Overall VOC & HAP Control Efficiency °A:
Limited Process Parameter
uCf'iyrM
�h>
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
VRU Downtime/Bypass (%)
Actual Throughput =
Actual Throughput Controlled By VRU =
Actual Throughput Controlled By ECD =
Requested Permit Limit Throughput=
Requested Permit Limit Controlled By VRU =
Requested Permit Limit Controlled By ECD =
VRU with 50%Downtime, and eleven (11) Cimarron 48" and one (1) Cimarron 60" Enclosed Flares.
100.00
95.00
97.50
163,315 bbls at 100% Control MR of throughput to VRU) +
163,315 bbls at 95% Control (50%of throughput to Enclosed Combustor).
50.00%
326,630.0 Barrels (bbl) per year
163,315.0 Barrels (bbl) per year
163,315.0 Barrels (bbl) per year
326,630.0 Barrels (bbl) per year Requested Monthly Throughput= 27741.2 Barrels )bbl) per month
163,315.0 Barrels (bbl) per year
163,315,0 Barrels(bbl) per year
Potential to Emit (PTE) Condensate Throughput =
326,630.0 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per BBL of liquids
Molecular Weight=
VOC mol%=
Molar Volume=
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2540.6 Btu/scf
scf/bbl
.45.3 Ib/Ibmol
67.3%
379.4 scf/Ibmol
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
14,968.6 MMBTU per year
14,968.6 MMBTU per year
14,968.6 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
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
2.9001E+00
7.2503E-02
Site Specific E.F.{includes flash)
Site 5p cifrr J.F.{includes flash)
'includes flash)
Includes flash)
des flash)
S es flash) '� r
Ste p,.,. .. des flash) a
Benzene
6.225E-03
1.556E-04
Toluene
8.181E-03
2.045E -04,x..
Ethylbenzene
2.296E-04
5.740E-06
Xylene
3.014E-03
7.534E-05
n -Hexane
5.788E-02
1.447E-03
224 TMP
.2.683E-04
6.708E-06
Pollutant
Control
Device
Emission Factor source
Uncontrolled
Uncontrolled
(Ib/MMBtu)
(lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.0075
3.41E-04
AP -42 Table ^ k=2 (PM10/PM.2.5)
AP -42 Table 1.:4-2 (PM30/PM 25)
other -:Explain
TNRCC Flare Emissions 'Guidance (NO X),
TNRCC Flare Erissions Guidance (CO)
PM2.5
0.0075
3.41E-04
SO
0.0006
2.70E-05
NO
0.1380
6.324E-03
CO
0.2755
1.263E-02
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/MMscf)
(Pilot Gas Heat
Combusted)
(Pilot Gas
Throughput)
PM10
0.0075
8.5
2{PM10/PM.2.5)
-PM10_/PM.2.5)
{
,,.... P. - z
PM2.5
0.0075
8.5
SO x
0.0006
0.7
NOx
0.0680
77.2
VOC
0.0054
6.1
CO
0.3100
352.2
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
it
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
3 of
K:\PA\2018\18WE1018.CP2
Storage Tardgs) Emissions Inventory
PM10
PM2.5
sox
NOx
VOC
CO
0.1
0.1
0.1
0.1
0.1
10.7
0.1
0.1
0.1
0.1
0.1
10.7
0.0
0.0
0.0
0.0
0.0
0.8
1.1
1.1
1.1 -
1.1
1.1
186.2
473.6
473.6
11.8
473.6
11.8
2012.2
2.4
2.4
2.4
2.4
2.4
399.3
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Has/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) llbs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year}
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
2033
2033
51
2033
51
2672
2672
67
2672
67
75
75
2
75
2
984
984
25
984
25
18904
18904
473
18904
473
88
88
2
88
2
4 of 7 KAPA\2018\18W E1018.CP2
Storage Taani* Emis 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 LOT
Regulation 7, Part D,Section I.G, C
Storage Tank is not subject to Regulation 7, Section I.G
Regulation 7, Part D,Section II.B, C.1, C.3
Storage tank is subject to Regulation 7, Part D, Section II, B, C.1 & C.3
Regulation 7, Part D,Section lLC2
Storage tank is subject to Regulation 7, Part D, Section ll.C.2
Regulation 7, Part D,Section II.C.4.a.(i)
Storage Tank is not subject to Regulation 7, Part 0, Section II.C.4.a(i)
Regulation 7, Part D,Section ll.CA.a.(ii)
Storage Tank is not subject to Regulation 7, Part 0, Section 14C.4.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 8, Part E, MACE 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 to
estimate emissions? 4 '
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
controlled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
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? a75!:i..•
-
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 -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.�yts
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 a control 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 thelosephine
19M-234well. This well isone of the thirteen (13) wells drilled at this facility and there were no signifiant changes to the facility since the development of the emissions factors. Asa result, they 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 tempeature and pressure in 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 (MMHtu/yr) _ [Uncontrolled VOC (ton/yr)] e [2000(tb/ton)] _ MW (lb/lbmol) « [379.41(sof/lbmol)] s [1/VOCmoI %] . [Heat Con tent (Btu/scf)] • [1MMBtu/(1000,000 Btu)].
The values used in the equation were obtained from a Pro Max simulation used to calculate emissions and to develop emission futon The values used are as follow:.(i) Molecular weight: 45.31b/Ib-mol, (ii) VOC mol %:
67.3 %, (Iii) Heat Content:. 2540.6 Btu/scf.
3. Pilot Light Emissions Calculations: Operator assumed pilot fuel to have the same conditions of field gas which is consistent with the plant design provide by o perator. The permit will not contain initial or periodic
opacity testing for the enclosed combustors) because the 0&M plan approved for this source requires weekly visible emissionsobservations of the enclosed combustor(s). A throughput limit is included in the permit
for pilot combustion. Emission factors and calculation methods for pilot light combustion emissions are also included in thenotes to permit holder. This information is included in the permit because pilot light
emissions contribute to the overall emissions from this source.Additionally It is important to. include this information became throughput tracking and emission calculation methods are different than those used to
estimate emissions based on the condensate throughput. This clarity is important for accurately quantifying actual emissionsat this facility.
4. Self -certification submittal and approval: Self -certification was. submitted by operator on 02/18/2020. The Division approved self -certification on 03/18/2020:
_ 5. Operator expressed concerns about rounding issues related to the VOC emissions limit. VOC requested emissions limit is11:84593 tpy, which when rounded to three significant figures as ltisthe. Division's practice,
VOC requested limit is 118. tray. Operator expressed that they are concerned that the point source might be out of complicanceif emission were to be 1182 tpy (e.g.); therefore, permit limit forVOC will be rounded
up to 11.9 tpy.
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
AIRS Point ff
017
Uncontrolled
Emissions
Process It SCC Code .Pollutant Factor Control% Units
01 .4.4403.31 fixerfRoofTank,. Goru#erssate,,working+bregthinisfliafulolosses - , PM30 0.01 0 lb/1,000 gallons Condensate throughput
PM2.5 0.01 0 lb/1,000 gallons Condensate throughput
SOx #REF! 0 lb/1,000 gallons Condensate throughput
NOx 0.16 0 lb/1,000 gallons Condensate throughput
VOC 69.05 98 lb/1,000 gallons Condensate throughput
CO 0.34 0 lb/1,000 gallons Condensate throughput
Benzene 0.15 98 lb/1,000 gallons Condensate throughput
Toluene 0.19 98 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.01 98 lb/1,000 gallons Condensate throughput
Xylene 0.07 98 lb/1,000 gallons Condensate throughput
n -Hexane 1.38 98 lb/1,000 gallons Condensate throughput
224 TMP 0.01 98 lb/1,000 gallons Condensate throughput
)
5 of 7 K:\PA\2018\18WE1018.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
Ses.ae is n, the Nun r?.airimunt Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY(Regulation 3, Part A,Sectlon ll.D.l.a)7 Source Requires an APEN. Go to
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05.01 Definitions 1.12 ard1.14 and Section 2 for additional guidance on grandfathenapplicability)7 Go to next question
3. Are total facility uncontrolled VOC emissions greater than 5TPY, NOx greater than lO TPY or CO emissions greater than 10 TPY(Regulation 3, Part B, Section ILD31? Source Requires a permit
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3, Part A, Section IID.l.a)7
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05.010efinitlons 1.12 ard1.14 and Section Mar additional guidance on grandfather appllabl.)?
3. Are total facility uncontrolled VOC emissions greater than 2TPY, NOx greater than 5TPY or CO emissions greater than 10 TPV(Regulation 3, Part B Section 11.0.2)2
Colorado Regulation 7. Part D, Section I.C-F &G
1. Is this storage tank located in the e' -hr ozone control area or any oxonenon-attainment area or attainment/maintenance area(Regulafon 7, Part D, Section lA.3)?
2. Is this storage tank located at oll and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that areilocated at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A:l)?
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section LC)?
4. Does this storage tank contain condensate?
S. Does this storage tank exhibit "Flash'. (e.g. storing non -stabilized liquids) emissions(Regulation], part 0, Section Lag)?
6. Are uncontrolled actual emissions of this stooge tank equal to or greeter than 2tons per year VOC (Regulation 7, Part 0 Section l.D.3ttlii)?
on I,C r
Penn, 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.D— Emaslons Control Requirements
Part 0, Section IX —Monitoring
Part D, Section I.F —Recordkeeping and Reporting
Is :: -c., 7.Scrtiun G
Part D, Section I.G.2- Emissions Control Requirements
Part 0, Section I.C.1.a and b —General Requirementsfor Air Pollution Control Equipment —Prevention of Leakage
Colorado Regulation 7. Part D. Section II
1. Is this staragetank located at a transmission/storagefaciliry?
2. Is tho storage tanks located at an ail and gas exploration and production operation, well production facility', natural gas compressor station or natural gas processing plant'(Regulation 7, Part D, Section ll.C)?
3. Does this storage tank have a fixed roof (Regulation 7, Part&Section ll.A.10)7
4. Are uncontrolled actual emissions of this storagetank equal to or teeter than 2 tons per year VOC (Re gulation], Part D,Sectlon ll.CLc)?
I -3.tordue mirk isaubjuai. Fivaidarivg 7. Part Ir.5
Part D, Section II.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part. D, Section II.G3 - Emkslons Control and Monitoring Provisions
Part. D, Section II.C.3- Recordkeeping Requirements
5. Does the storage tank contain only"stabilized?liquids(Regulation 7, Part D, Section ll.C2.b)?
gota;="fi'`'at^:
won
Source Requires an APEN. Go to
Go to next question
Source Requires a permit
:ontlnue-You have Indicated th
.ontlnue - You have indicated th
storage Tank is not subject to Re
Continue - You have indicated th
Go to the next question- You ha
Go to the next question
Source. Is subject to parts of Reg
Part D,Section llC2 Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Isthe 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 1, 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 CAa(d7 Nq,... +' Storage Tank h not subject to Re
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or afterlanuary 1,
7. 2021, such that an additional controlled storage vessels constructed to receive an anticipated Increase in throughput of hydroarhan iqu ds or produced water (Regulation 7, Part D, Section II.C.d.a(I )7
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 (m') F-472 BBts) (40 CFR 60.110b(a))?
2. Does the storage vessel meet the following exemption in 60.1116(d)(4)7
a. Does the vessel has a design capacity lessthan or equal to 1,589.874 m'("10,000 BBL] used for petroleum' or condensatestored,processed, or treated prior to custody transfer' as defined in 60.111b7
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 19B4(40 CFR60.110b(a))? '
4. Does the tank meet the definition of"storage vessel.' in 60.111b1
5. Does the storage vessel store a"volatile organic liquid lVOL)"'as defined in 60.1116?
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))7; or
b. The design capacity is greater than or equal to 1510 (-950 BBL) and stores a liquld with a maximum true vapor pressure' less than 3.5 kPa (60.1306(6))7; or
c. The design capacity Is greater than or equal to 75 Ms (-472 BBL) but lessthan 151m3 (`950 BBL) and stores a liquid with &maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
Does the storage tank meet either one of thefollowing exemptlonsfrom control requirements:
a. The design capacity Is greater than or equal to 1510 (-950 BBL] and stores a liquid with a maximum true vapor pressuregreater than or equal to 3.5 kPa but less than 5.2 kPa?; or
b. The design capacity is greater than or equal to 75 Ms (-472 BBL) but less than 151 m' (^950 BBL) and stores aliquid with &maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa?
I5tpra La Tank is nut miak.ci arrPSMb
40 CFR. Part 60, Subpart 0000/0000a,Standards of Performance for Crude 011 and Natural Gas Production, Transmission and Distribution
1. Is tho storage vessel located at a facility in the onshore all 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, 60.2) between August 23, 2011 and September 18, 20157
3. Was this storage vessel constructed,reconstructed, ar modHled(see definitions 40 CFR, 60.2) after September 18, 2015?
4. Are potential VOC emissions' from the individual storage vessel greater than or equalto 6tons per year?
5. Does this storage vessel meet the definition of"storage vessel.' per 60.5430/60.5430a?
6. Is the storage vessel sublect to and controlled in accordance with requlrementz for stora a vessels in 40 CFR Part 60 Sub art Kb or .CFR Part 63 Sub art HH2
Naga
(Note: If a storage vessel Is previously determined m he subject to NSPS 0000/0O0Oa due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per
60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT NH, OII and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. Afacility that processes, upgrades or sores hydrocarbon liquids (63.760MM; OR
b. Afacility thatprocesses, upgrades or stares natural gas priorto the point at which natural gas enters the natural gas transmbsion and storage source category or is delivered to a final end use,' i63.]60(a)(3))7
2. Is the tank located at a facility that b major'fbr HAPs7
3. Does the tank meet the definition of"storage vesseln' 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 sublect to control re q uirements under 40 CFR Part 60, Sub art Kb or sub art 0000?
I 6
Subpart A, General provisions per 463.764 (a) Table 2
463.766- Emissions Control Standards
463.773 -Monitoring
463.774-Recordkeeping
463.775 -Reporting
RACE Review
RACT review Is required If Regulation ] does not apply AND if the tank Is in the non -attainment area. lithe tank meets bath criteria, then review RACT requirements.
Disclaimer
Go to the next question
Storage Tank is not subject NSPS
Continue -You have Indicated th
Storage Tank Is not subject N5P'
Go to the next question
Storage Tank is not subject NSPS
ontinue - You have indicated th
torageTank is not subject MAC
Thisdocument assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Contra/ Commission regulations. This document is not
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 end is nht 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 nonunendelory language such as "recommend,""may,""should,"end 'can,"is intended to
describe APCO 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
Chiefly Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
JUL 3 1 2020
Condensate Storage Tank(s) APEN
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: 17WE0552
AIRS ID Number: 123 / 9F2B /001
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Klein 19 Sec Pad 1; Josephine 19 Sec HZ
Site Location: SWNE Sec 19 T5N R64W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAILS 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.
tisv�7
F,:;rri APC.t 'w'_ L)ralei;5P .KI'i-'# 't5: ,r ,_. 1 I a®
COLORADO
Depatnw�—iu•Isanar t
Permit Number: 17WE0552
AIRS ID Number: 123 / 9F2B / 001
[Leave blank unless APCD has already assigned a permit 1) and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GPO8
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR -
▪ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name;
Q Change permit limit ❑ Transfer of ownership' ❑ 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 & Notes: Requesting new throughput limit and emissions limits for Construction Permit 17WE0552;
2019 Actual throughput; Emissions calculated using previously approved site -specific emission factors.
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
2/24/2017
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
hours/day 7 days/week
Storage tank(s) located at: 0 Exploration Et Production (EEtP) site
52
weeks/year
❑ Midstream or Downstream (non EfiP) site
Will this equipment be operated in any NAAQS nonattainment area?
V
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
GI
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
O
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.004329
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
■
12
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualGI
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 12/2019
2,14®I
COLORADO
dam.-.d..�
�•'swi s.
Permit Number: 17WE0552
AIRS ID Number: 123 / 9F2B / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limits
(bbl/year)
Condensate Throughput:
218,422
218,422
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 50.6 degrees
❑ Internal floating roof
Tank design: El Fixed roof
RVP of sales oil: 8.5
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TK-1 (1)
8
4,304
6/2016
2/2017
Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 40145
Klein 19N-302
■
05
- 123
- 40150
Klein 19N-432
■
05
- 123
- 40148
Klein 190-212
■
05
- 123
- 40147
Klein 190-232
■
05
- 123
- 40151
Klein 190-302
■
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.
6 The MP 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 IITM)
40.385396/-104.592178
❑ 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)
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 12/2019
3 I aal
COLORADO
amalft ..�.
Permit Number: 17WE0552
AIRS ID Number: 123 / 9F2B / 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
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
Type: Endosed Combustors Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 95 %
Minimum Temperature:
6 x Cimarron 48", 1 x Cimarron 60"
Waste Gas Heat Content:
Constant Pilot Light: El Yes ❑ No Pilot Burner Rating:
2,333
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 (EEP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 32 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
_ ' r1 FiQ L. De2C.i
4ilgeI
COLORADO
O�p�vraNluYM
Mal* Y fpAYangwll
Permit Number: 17WE0552
AIRS ID Number: 123 / 9F2B / 001
[Leave blank unless APCD has already assigned a permit 11 and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? Q 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)
VOC
Enclosed Combustors
100%
95%
NOx
CO
HAPs
Enclosed Combustors
100%
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
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
tons/ ear
( Y 1
Controlled
Emissionse
(tons/year)
Uncontrolled
Emissions
tons/ ear
( Y 1
Controlled
Emissions
tons/ ear
( Y )
VOC
2.0326
lb/bbl
ProMax
221.98
11.10
221.98
11.10
NO.
0.1380
IbIMMBtu
TCEQ
N/A
120
N/A
120
CO
0.2755
lb/MMBtu
TCEQ
N/A
2.50
N/A
2.50
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.
e 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
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the fallowing table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor?
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg.,etc.)
Uncontrolled
Emissions
(Ibs/year)
Controlled
Emissionse
(Ibs/year)
Benzene
71432
0.0058
lb/bblProMax
1,269.02
63.45
Toluene
108883
0.0061
lb/bbl
ProMax
1,333.47
66.67
Ethylbenzene
100414
0.0002
lb/bbl
ProMax
43.77 (DM)
2.19 (DM)
Xylene
1330207
0.0026
Iblbbl
ProMax
558.59
27.93
n -Hexane
110543
0.0423
lb/bbl
ProMax
9,231.50
461.58
2,2,4-Trimethylpentane
540841
0.0004
Iblbbl
ProMax
84.59 (DM)
4.23 (DM)
Yes ❑ 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.
e Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
DC 12/03/2020. Per
attached email.
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
COLORADO
5 I � xn�,
Permit Number: 17WE0552
AIRS ID Number: 123 / 9F2B / 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.
re of Legally Authorized Person (not a vendor or consultant) r Date
ack Starr Senior Air Quality Representative
Name (print) Title
Check the appropriate box to request a copy of the:
❑r 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
n(s) .'j2L"N - if V45E >
614O
COLORADO
mwae.erNike
ENNIO imleenMY
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
PDC Energy, Inc.
Source Name:
Klein 19 Sec Pad 1; Josephine 19 Sec HZ
Emissions Source AIRS ID2:
123 / 9F2B / 001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 40146
Klein 190-402
■
05 - 123 - 40149
Klein 19P-202
❑
05 - 123 - 40155
Klein 19P-312
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
■
- -
❑
- -
❑
- -
■
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
■
Footnotes:
I 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 1D by the APCD, enter
N/A
Form APCD-212
TK-1 (1)Addendum
.a
31St 11 baa
Condensate Storage Tank(s) APEN
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
fora 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: 18WE1018
AIRS ID Number: 123 / 9F2B /017
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Klein 19 Sec Pad 1; Josephine 19 Sec HZ
Site Location: SWNE Sec 19 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
' 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 wilt require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form ,fir.;; i', 7g.e ankts) APErsi
V(39,1/,e
4201
COLORADO
p�loma s .e
Permit Number: 18WE1018
AIRS ID Number: 123 / 9F2B / 017
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
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 $312.50 must be
submitted along with the APEN filing fee.
-OR-
I] MODIFICATION to existing permit (check each box below that applies)
Ei Change in equipment ❑ Change company name;
El Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
OR -
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
s
Additional Info Et Notes: Requesting new throughput limit and emissions limits for Construction Permit 18WE1018;
2019 Actual throughput; Emissions calculated using previously approved site -specific emission factors.
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose:
Company equipment Identification No. (optional):
For existing sources, operation began on:
Condensate Storage Tanks
TK-1 (2)
6/18/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day
Storage tank(s) located at:
7
0 Exploration Et Production (E&P) site
days/week
52
weeks/year
❑ Midstream or Downstream (non E$P) site
Will this equipment be operated in any NAAQS nonattainment area?
GI
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
17
Yes
■
No
Is the -actual annual average hydrocarbon liquid throughput .≥ 500 bbl/day?
GI
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.005437
m'/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
■
D
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualGI
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 12/2019
2,461
COLORADO
ne,eaaa.ar"Abe
Holt% .a...aa_a
❑ Upward
❑ Horizontal
Permit Number: 18WE1018
AIRS ID Number: 123 /9F26/017
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limits
(bb(/year)
Condensate Throughput:
326,630
326,630
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 51.4 degrees
❑ Internal floating roof
Tank design: ❑r Fixed roof
RVP of sales oil: 8.7
❑ 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 (2)
15
7,832
7/2017
1/2001
Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 44679
Josephine 19M-234
■
05
- 123
- 44682
Josephine 19M-334
■
05
- 123
- 44674
Josephine 19M-404
■
05
- 123
- 44676
Josephine 19N-204
■
05
- 123
- 44672
Josephine 19N-214
■
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.
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)
40.385396/-104.592178
❑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)
Indicate the direction of the stack outlet: (check one)
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack depth (inches):
3 , 6®1
COLORADO
11.11.1•10.nesent
Permit Number: 18WE1018
AIRS ID Number: 123 / 9F2B / 017
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
0 Recovery
Unit (VRU):
Pollutants Controlled: VOC and HAPs
Size: Make/Model: EcoVapor Compressor
Requested Control Efficiency: 100 %
VRU Downtime or Bypassed (emissions vented): 50 %
Q Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu / hr
Type: Enclosed Combustors Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature:
11 x Cimarron 48", 1 x Cimarron 60"
Waste Gas Heat Content:
Constant Pilot Light: Yes ❑ No Pilot Burner Rating:
2,541
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 (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 22,2 psig
Describe the separation process between the well and the storage tanks: High/LOW Pressure Separator
4Ile®
COLORADO
u.a.a.aedrawt
e.A,mwanm."
Permit Number: 18WE1018
AIRS ID Number: 123 / 9F2B / 017
[Leave blank unless APCD has already assigned a permit q and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN fore.
Is any emission control equipment or practice used to reduce emissions? El 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
(96 reduction of captured
emissions)
V0C
Endosed Combustors
100%
97.50%
NOx
CO
HAPS
Enclosed Combustors
t00%
97.50%
Other:
From what year is the following reported actual annual emissions data? 2019
Use the followinsZ table to report the criteria pollutant emissions from source:
Pollutant
Emission Factor7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(�-/2,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions$
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
2.9001
lb/bbl
ProMax
473.64
11.85
473.64
11.85
NO.
0.1380
Ib/MMBtu
TCED
N/A
1.10
N/A
1.10
CO
0.2755
lb/MMBtu
ICED
N/A
2.35
N/A
2.35
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 ADEN 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
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
Service (�)
Number
Emission Factor7
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(Ibs/year)
Controlled
Emissions8
(Ibs/year)
Benzene
71432
0.0062
lb/Obi
ProMax
2,033.14
50.83
Toluene
108883
0.0082
Iblbbl
ProMax
2,67227
66.81
Ethylbenzene
100414
0.0002
Iblbbl
ProMax
74.99 (DM)
1.87 (DM)
Xylene
1330207
0.0030
Iblbbl
ProMax
984.38
24.61
n -Hexane
110543
0.0579
lb/bbl
ProMax
18,903.99
472.60
2,2,4-Trimethylpentane
540841
0.0003
lb/bbl
ProMax
87.64 (DM)
2.19 (DM)
El Yes ❑ 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.
B Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 12/2019
COLORADO
lima Sepadnaagaablie
o,.
Permit Number: 18WE 1018
AIRS ID Number: 123 /9F26/017
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 ure of Legally Authorized Person (not a vendor or consultant)
Jack Starr
Name (print)
i( 3o,/Zo zO
Date
Senior Air Quality Representative
Title
Check the appropriate box to request a copy of the:
❑r 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 For more information or assistance call:
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-61
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Small Business Assistance Program
(303) 692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303)692-3150
Form APC^•2 C �
v.`s �r iU ..t.�r.C.:. Sicorz. 111 .t$I APEN -Revision_ •:.1, t
6 116®1
COLORADO
wi.mm .�..`i
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml
Company Name:
PDC Energy, Inc.
Source Name:
Klein 19 Sec Pad 1; Josephine 19 Sec HZ
Emissions Source AIRS ID2:
123 / 9F2B / 017
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 44678
Josephine 19N-314
❑
05 -123 - 44673
Josephine 19N-334
■
05 - 123 - 44677
Josephine 19N-404
❑
05 - 123 - 44681
Josephine 190-204
❑
05 - 123 - 44675
Josephine 19O-214
❑
05 - 123 - 44680
Josephine 19O-314
❑
05 - 123 - 20129
Seth 1
❑
05 - 123 - 24774
Seth 5 '
❑
- -
❑
- -
❑
- -
■
- -
■
- -
■
- -
■
- -
■
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
TK-1 (2) Addendum
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