HomeMy WebLinkAbout20210211.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150OSt.
PO Box 758
Greeley, CO 80632
January 13, 2021
Dear Sir or Madam:
RECEIVED
JAN 1 9 2021
WELD COUNTY
COMMISSIONERS
On January 14, 2021, the Air Pollution Control Division will begin a 30 -day public notice period for
PDC Energy, Inc. - Sanford 21-29 Pad. 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 £t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
Pubi, C Rev;e(„)
0l/25/aI
Cc:PL.(TP) H(DsIT-R) PW(stAIER/cHlcK)
oG(ari) '
01 /20/21
F . c„o46- .t.
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Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Sanford 21-29 Pad - Weld County
Notice Period Begins: January 14, 2021
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: Sanford 21-29 Pad
Well Production Facility
NENW of Section 29, Township 5N, Range 66W
Weld County
The proposed project or activity is as follows: PDC Energy Inc. submitted an application requesting permit
coverage for condensate storage vessels, produced water storage vessels, and hydrocarbon liquid loadout at
a new synthetic minor oil and gas well production facility located in the ozone non -attainment area.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0495, 20WE0496 Et
20WE0497 have been filed with the Weld County Clerk's office. A copy of the draft permit and the
Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-
permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.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:
Harrison Slaughter, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of public
Health 6 Environment
COLORADO
Air Pollution Control Division
oepar rrent a" Pun:: Health 6 Erlv>rervnervl
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0495 Issuance:
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County.:
Description:
PDC Energy, Inc.
Sanford 21-29 Pad
123/AOF2
NENW SEC 29 T5N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
1
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-1
002
Six (6) 400 barrel fixed roof condensate
storage vessels connected via liquid
manifold.
Emissions from the
storage vessels are
routed to a sales
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 35% 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
Page 1 of 12
!COLORADO
Air Pollution Control Division
Department a' Puhlr Health b Envtrcnrneu
Dedicated to protecting and improving the health and environment of the people of Colorado
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 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.)
3. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4. 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
5. 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
002
---
1.5
14.6
3.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant 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 both 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.
6. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
Page 2 of 12
a
COLORADO
Air Pollution Control Division
Devartrnent d Publ4 Health b Envlrivvnent
Dedicated to protecting and improving the health and environment of the people of Colorado
contained in this permit. 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.
7. 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
002
Emissions from the storage vessels are
routed to a sales 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
35% annual downtime.
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. 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,
Section II.A.4
Process Limits
Facility
Equipment
ID
AIRS
Point
Process
Process Parameter
Annual Limit
TK-1
002
01
Total condensate
throughput
1,659, 360 barrels
Condensate
throughput during
VRU downtime
580,776 barrels
02
Combustion of pilot
light gas
0.6 MMSCF
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator must 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
Page 3 of 12
Air Pollution Control Division
I D'le^stanment a' PuGtr_ Health 6 raor farle"a
Dedicated to protecting and improving the health and environment of the people of Colorado
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
10. 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)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. 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 visualobservation 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)
13. 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.24; 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.
14. 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.
15. 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.
16. 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
Page 4 of 12
COLORADO
Air Pollution Control Division
Depari TTent co Pun:: Health b rnvirimme-A
Dedicated to protecting and improving the health and environment of the people of Colorado
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
17. Upon startup of this point, the owner or operator must follow the most t recent operating and
maintenance (OEtM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the OEtM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
18. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. This permit replaces the following permits and/or points, which are cancelled upon issuance
of this permit.
Existing Permit
Number
Existing
Emission Point
New Emission Point
GP10
123/A0F2/001
123/A0F2/002
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
Page 5 of 12
COLORADO
Air Pollution Control Division
De%ranrneni a' Publr_ Flea i b TnainVirne-v,
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
22. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D Section VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Facility
Equipment
ID
AIRS
Point
Equipment
Description
P
Pollutant
Emissions - tons per year
Threshold
Current
Permit
Limit
---
001
Well
Maintenance/
Unloading
NOx
VOC
50
50
17.1
40.1
TK-1
002
Condensate
Storage
Vessels
TK-2
003
Produced
Water
Storage
Vessels
LOAD -1
004
Hydrocarbon
Loadout
ENG-1
006
SI RICE
Page 6 of 12
COLORADO
Air Pollution Control Division
Clepanment of Putl4 Health 6 ErYvirwmell
Dedicated to protecting and improving the health and environment of the people of Colorado
ENG-2
007
SI RICE
GEN-1
008
SI RICE
GEN-2
009
SI RICE
___
___
Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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.
25. 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.
26. 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.
27. 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.
Page 7 of 12
COLORADO
Air Pollution Control Division
`w':8anrnent o' Publ4 Health 6 tnvirQame,a
Dedicated to protecting and improving the health and environment of the people of Colorado
28. 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.
29. 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:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Permit for condensate storage vessels at an oil
and gas well production facility.
Page 8 of 12
COLORADO
Air Pollution Control Division
Deaaanenl a? Putar, I fealth 6 Enofrcfutte•51
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-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr) `
Controlled
Emissions
(lb/yr)
002
Benzene
71432 '
4,809
84
Toluene
108883
6,452
113
Ethylbenzene
100414
140
2
Xylenes
1330207
2,263
40
n -Hexane
110543
43,266
757
2,2,4-
Trimethylpentane
540841
113
2
ote: All non -criteria reportable pol utants in the table above with uncontrolled emission rates above 250 pounds per year
( b/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 9 of 12
COLORADO
Air Pollution Control Division
De.a3r med al PuGGC Heel! b _rnnrtrviieni
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 002:
Process 01: Condensate Throughput
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission Factors
When Emissions
are Routed to
the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
NOx
5.09x103
---
5.09x10-3
TNRCC
CO
1.02x10-2
---
1.02x10-2
V0C
1.003
0.00
5.016x10-2
ProMax
71432
Benzene
2.898x1O3
0.00
1.449x10-4
108883
Toluene
3.888x10-3
0.00
1.944x10-4
1330207"
Xylenes
1.364x103
0.00
6.818x10-5
110543
n -Hexane
2.607x102
0.00
1.304x10-3
Note:
The controlled emissions factors for this point are based on a control efficiency of 100% when
emission 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 emission factors for this source
were developed using a site specific pressurized liquid sample in conjunction with ProMax. The
pressurized liquid sample used as an input for the ProMax simulation was obtained from the
outlet of the gas buster for all the wells at this facility on 04/23/2020. The sample temperature
and pressure are 107°F and 19.9 psig respectively.' Uncontrolled actual VOC and HAP emissions
are calculated by multiplying the emission factors in the table above by the total condensate
throughput. Controlled actual VOC and HAP emissions are calculated by multiplying the
uncontrolled emissions by a 100% control efficiency when emissions are routed to the VRU and a
95% control efficiency when emissions are routed to the enclosed combustor(s) during VRU
downtime. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission
factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to
units of lb/bbl using a GOR of 15.408 scf/bbl and heat content of 2,392.31 Btu/scf. Actual NOx
and CO emissions are calculated by multiplying the emission factors in the table above by the
total condensate throughput during VRU downtime.
Process 02: Combustion of pilot light gas
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/MMSCF)
Controlled
Emission
Factors
(lb/MMSCF)
Source
N0x
77.25
77.25
AP -42 Chapter 13.5
CO
352.16
352.16
V0C
6.13
6.13
AP -42 Chapter 1.4
Table 1.4-2
Page 10 of 12
COLORADO
Air Pollution Control Division
C�.,sgrnent eA Pubbc health b Envireornent
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: 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 ratio of 1,136 Btu/scf to 1,020 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. Monthly pilot light gas
throughput shall be determined by multiplying this hourly pilot gas throughput by the monthly hours
of operation of each combustor. There are four (4) enclosed combustors, each equipped with a
single pilot light, used to control emissions from the condensate storage vessels during VRU
downtime.
Total actual emissions are obtained from the sum of emissions resulting from the storage
vessels and combustion of waste gas from the storage vessels (process 01) and the combustion
of pilot light gas (process 02).
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 validpermit 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, CO, n -Hexane Et Total HAP
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC Et NOx
MACT HH
Area Source Requirements: Not Applicable
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
Page 11 of 12
COLORADO
Air Pollution Control Division
C ef.Aan rieit ce PuG1Y_" Health 6 ErlvirCiltnent
Dedicated to protecting and improving the health and environment of the people of Colorado
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 12 of 12
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package It
Received Date:
Review Start Date:
For Division Use Only
Harrison Slaughter
430833
5/4/2020..
10/19/2020
Section 01- Facility Information
Company Name: PDC Energy, in
County AIRS ID: 123
Plant AIRS ID: ;A0P2
Facility Name: Sanford 21-29 Pad.
Physical _
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
'
What industry segment Od"& Natural Gas Production & Processing .-
Is this facility located in a NAAQS non -attainment area? Yes:. '
If yes, for what pollutant? ;Ozone (NOx & VOC)
Weld County
Section 02 - Emissions Units In Permit Application
Leave Blank - For Division Use Only
AIRS Point if
(Leave blank unless
APCD has already
assigned)
Emissions Source Type
Equipment Name
Emissions
Control?
Permit tl
(Leave blank unless
APCD has already
assigned)
Issuance
0
Self Cert
Required?
Action
Engineering
Remarks
002
S#orage Tank
TK 1
Yes
20WE0495
1
Yes
Permit Initial
Issuance
Quadrant
Section
Township
Range
NENW
29=
Section 03 - Description of Project
_._ ..
PDC Energy, Inc. (PDC) submitted a permit application requesting' permit coverage for several new sources at a well production facility located in the ozone non -
attainment area. With this application, the, operator 1s requesting permit coverage for condensate' storage vessels, produced water storage vessels, hydrocarbon
�aiquid loadout, separator venting, and engines. The engines are requesting GP02 coverage. This analysis only evaluates the condensate,storage vessels.
This source is APEN required because uncontrolled actual VOC emissions aregreater than 1 tpy (CO AQCC Regulation 3, mart A, Section ILB.3.a). Additionally, the
?'source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facilityare greater than 2) py (CO AQCC Regulation 3,
:Part B, Sermon ILDt2.al. It should be noted that issuance of this Permitservesto cancel the GP10 coverage for this source.
Public comment is required because new synthetic minor limits are'being established with this application.
Sections 04, OS & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
Yes
-
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) OOOO
Title V Operating Permits (OP) ❑
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, indicate programs and which pollutants: SO2
Prevention of Significant Deterioration (PSo) OOOOO
Title V Operating Permits (OP) ❑
Non -Attainment New Source Review (NANSR)
No
Yes
NOx
O
O
Na'
NOx
❑
O
.
CO
O
Co
❑
VOC
O
O
VOC
❑
O
PM2.5 PM10 TSP HAPs
❑ ❑
❑ OOO
PM2.5 PM10 TSP HAPs
❑
❑ OLD
Storage-ank(s) Emissions Inventory
Seclion 01.Admmiso-atNe information
IFacllity Allis .
323
County
secdon 02- Equipment Description Uetalls
Storage Tank Liquid
Detailed Emissions Unit
Description:
Emission Contras Device
Description:
Ian)
do
Paint
Su (6j400 barrel axed roof d sate imrage vesielsu
Requested VRU Control Efficiency %:
ed via liquid manifold.
par recovery unit (VRU) routes emissions to pipeline. Emissions are muted to enclosed combusmr(s) during VRU downtime:.
100
Requested Endosed Combustor Control Efficiency%: 95
VRU Downtime %:
Requested Overall VOC IS HAP Control Efficiency%
Limited Process Parameter
Section 03- Processing Rate Information for Emissions Estimates
Primary Emissions -Storage Tank(s)
Actual Throughput
Actual Throughput During VRU Downtime=
'Requested Permit Limit Throughput=
Requested Permit Limit Throughput Dunng VRU
Downtime=
.00
y38;]yG Barrels lbbll per year
rrels(bbll per year
659360D'Barrels(bbll per year
Requested Monthly Throughput=
Barrels lb. per month
Potential to Emit (PTE) Throughput=
Potential to Emit (PTE) Throughput Oaring VRU
Downtime=
Secondary Emissions Combustion Device(s)
Heat content of waste gas �'.
Volume of waste gas emitted per BBL of liquids
produced=
Actual heat content of waste gas routed to combustion device=
Requested heat content of waste gas routed ro combustion device=
-.0 Barrels (MI) per year
654g?Bl Barrels)bbl) per year
55272.1 Barrels )bbl) per year
Potential to Emit IPTE) heat content of waste gas routed to combustion device=
Control Device
.7 MMRTU per year
21...1-0-1.5 MMBTII eery.,
23,4 'a MMBN per year
SeNon 04- Emissions Fa...Methodologies
Methodologies
Will this storage tank emit flash emissions?
Profiler:Flow Rate
Pollutant
Flash Gas(Ib/hr)
W5B Gas(Ib/brl
oral Waste Gas
rte llb/hr)
Source
VOC
1423939651
15.96230652
Lilo'
Benzene
0.426944
0.0300979
Va.¢
Q�*
Toluene
0.570675
0.0430291
Ethylbemene
0.0123434
0.00101354 -
1 .
ProMa
Xylem
0.194325
0.020937
0.21--
Pro Max
n -Hexane
3.21926
039613
0. it,.
ProMa
2.2,4-22.
0.00921268
0.0010125
2.01073036
Pro
82,296.00 bbl/year
Pollutant
o-ol Device
PaRutant
Pollutant
Section 05 Emissions Inventory
Condensate Tank
Uncontrolled
Controlled
(Ito/bbp
(Ih/bhl)
(condensate
Throughput)
(Condensate
Throughput)
Uncontrolled
(Ito/MMBtu)
Uncontrolled
(Ito/bbl)
Mot Light EmMions
Uncontrolled
Unco.roged
(Ito/MMssFJ
mburted
0.00
0.0006
0:0680
0050
0.3100
MEE
Emission Factor Source
Emisslon Factor Source
Emission Factor Source
0.00270422
Controlled Emisslon Factors Used In Permit
Pollutant
Controlled Emission Factors used during VRU
Operation(Ib/bbl)
Used Owing VRU Downtime
(lb/bbl)
Source
VOC
030
-
%%specific E.F.
Benzene.._
5E,,
,.oluene
Site specific E.F.
T
-
— _
%%specific E.F.
Fthylbenzene
4.3•30..E-05
%especific E.F.
gylene
'.
- - 'a -
Site specific E.F.
n -Hexane
oJ'
-_
%%specific F.F.
I 22GTMP
0-: P
'._',r-:._.,
%%specific E.F.
Criteria Pollutants
Potential%Emi[
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (fora/year)
Requested Permit Limits
Uncontrolled Controlled
(tom/year) Item/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
50g
NOx
VOC
CO
0.2-
0.On9
0.082.
n:032
1.3.4
0.032
O.O0
0.069
0.0x,
0.0032
13.9
0.00fi
0.505
0.005
0.000
0.6
i.1
1.40b
1.252
1.433
LOS
254.5
3),.:32.5
t'W.
12.1411
23 25
43.045
1 6-552
2474,4
....,:=
2.55'1
I.O.
512,3
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
ilbs/Yead II6s/rear)
Requested Permit Limits
Uncontrolled Controlled
fibs/year) (Ibs/year)
Benzene
Toluene
Ethylbemene
%ylene
n -Haan
224TMP
4,90E.6a
40,9
70.13
0451.80
5�=.0^_
9109
645,1.3:
i 2121
140.41
227,02
2.05
140.41
2262,
-
«.00
2252,4
39,0
-526636
36055.2a
630.92
45.0,15
- -
=?.PO
a.i001.61
1._..v
i...,
2of4
C:\Users\hsiaughl\Desktxp\I2iA0F2\20WE0495.CP1
St:Drage Tartar -Emissions inventory
Section o6. Regulators/Summary Analysis
Regulation 3, Pare A.B
S.W..
Regulation], Part OSectonl C, O, E,F
m.o.. emilm D.DS
Regulation], Part D,Section ID, C
_ ri tank is not w�hz=_.m?eyulatica,=, ilv:rG -
Regulation ], Part OSe..dB, CliC.3
:.rub _ is widsstM -otatlwi P. Puss. se fin lt,B, (.1 _ .;3
Regulation], Part DSectlon ltC.2
tcsw8esmnk is sub.,. Pffiffiffion 7. - ITC-2
C,2
Regulation], Part ChSectlon lLCd.adil
Sffivwc Tank to ffis mord..'.e e ciffiei 7,P i0,se 8.4111.
Regulation], Part 0,Sectlon ll.C.4.4.)
mom., Teich icr:4,W.,. RegulatIon'2, Pent. 3zc:lion Inn-ondilh-f
Regulation 6, PartA, NSPS Subpart Bb
Ttrit,,. ;ffili Is not subiscrsa NMS Ws
Regulation 6, PartA, NSPS Subpart 000O
Ti._..._ rd m nss sffidffimNSPS OM).
NSPS Subpart 00004
- t;ohiocita 445th Y_Ua
Regulation e, Part E, MAR Subpart HH
Tffings IN. is ittrimuhffii.MACTThi
ee regulatory.. eabllty war ksheetfmdefailed anatyus
Section 07. Mai and Periodic Sam.. and Testing Requirements
For condensate or crude oil tanks, does thecompany use the state default emissions factors to
estimate emissions]
If yes, are the uncontrolled actual or requested emissions fora crude oil tank estimated to be greater than. or equal to 20 tom VOC per year OR are the uncontrolled
actual or requested emissions for a condensate storage tank estimated to be greater than or equal to e0 toy?
dyes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines In PS Memo 1403.
Does the company use ante specific emissions factor to estimate emissions? f
If yes and if there are flash emissions, are the emissions factors based an a pressurized liquid sample drawn at the facility being
permitted lfor produced water tanks, a pressurize liquid sample must be analyzed using flash liberation anz.,ysis)?Thls sample
should be considered representative which generally means site -specific and collected within one year of the application received i1Fya.
date,However, if the facility has not been modified (ego no new wells brought an -line), then It may be appropriate to use an older r•
sitespecific sample.
lino, the permit will contain an Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
...be Company request a contra, device efficiency greater than 95%fora flare or combustion device?
dyes, the permltwlll contain initial and Iedodlc compliance testing In accordance with PS Memo 2.02
N/A -the operator developed site specific emission factors.
Section 08 -Technical Analysis Notes
1. Please reference the APEN submittedan 05/04/2020 for a list of the fourteen new wells at this facility.The wells associated with this tank battery were fractured between November 2019 and January 2020a. began production between January and February2020.
Eleven of the wells at this lac.. produce from the Niobrara formation. Two weilset this facility produce from the Carlisle-Codell-Port Hays formations: One well at this facility Codell-Fort Hays formations. the sample used to establish site.specific emission factors was
obtained on 04/23/2020 from the outlet of the gas buster atthis facility. Since th sample was obtalnedefter the wells at the facilitybegan production, Its acceptable forrestablishing site specific emission factors
2. The sample used to establish emission factors was obtained from die outlet of Ite gas buster for all of the wells at this facility on O4/23/2o20.Ttds Is the last separation step prior to the liquid being sent to the storage vessels. Additionally, the site specific sample used
to establish emissions factors for this source was obtained within a year of Me application, As a result, to permit will not require Initial testing in order ...ale a site specific sample. Itshould be noted that the sample includes sample probe temperature and pressure in
conjunction with gauge pressure and temperature. According to lab Information, the sample probe temperature and pressure are obtained using lab equipment during the sampling process These values are emected to be more accurate compared to the gauge values
and are accepfable for use In the simulation to establish site specific emission factors
3. The site specific sample was used In conjunction with a ProMax simulation to determine site specific emission factors and combustion emission, The results of the simulation (ie emissore lib/yeri) are available far reference in Sectors 03 and 04 above.
4, The condensate storage vessels and produced water storegevessels are controlled by the same four loci combustors. As a result, engineeringgida d that b I (I NOx andC)fro ll the sources are summed together mord. to
determine APEN applicability. In this case, total NOx and.COemissions from all. sources are above APEN reporting thresholds Asa result, the permit for each source will contain emission limits and emission factors for NOx and CO. -
5.Sisar the condensate storage vessels and produced water storage vessels are controlled by a common control device, pilot light emissions are grouped with the highest emitting source covered by an In&vidal permit M this case, The condensate storage vessels are the
highest emitting source. As a result, pilot light emissions are accounted for with thlsanalysis. The permit for the condense te storage vessels also contains a throughput limit Mr pilot combustion. Emission factors and calculation methods for pilot light combustion
emissions are also included in the notes. permit holder. This information is included in the permit bemuse pilot light emissions contribute to Me overall emissions from this source. Additionally it is Important to irklede this Information because throughput tracking and
emission calculation methods are differ*. than those used toestmate emissions based on the crodegil Throughput This clarity is important for accurately quantifying actual.ernissions at this facility.
s. Initial and periodic opacity observations are addressed by Me O&M plan. As a result the permit derrot contain initial or periodic opacity testing...'
7. TypIW ly, the secondary combustion emissions are calculated using the waste gas flow rate and heat content predicted by the model used to esiabfsh the site -specific emissions factors. Based on the ProMax simulation Me total wastages flow rate was pre&cted to be
0,04494539 MMscf/day (flash antl W&B gas). Additionally, an average beat content was determined using the heat content of the flash gar stream (2392.31 Btffiscf) ant the W&B stream (2540.66 Btu/scf) and the following equations:
Average Heat Content 1i2392,31840/s011o.040694?MMscf/day)/10.04494539 MMscf/dayll+[(2540.64 BN/scf)•(O.004250e9 MMscf/dey)/(0.09494539 MMscf/dayl) A 2906.30tu/scf
Using Misinformation, the yearly heat input of the gaswehEne calculated as WM.,' Heat lnput(MMRM/yr)=10.04494539MMscf/day}•(365d j./M.*(24.6.3 MdiTT9NMscfT10.35)=J3,g16.?.... year Using this value, the actual NOx and CO emissions would.
be calculated at 0.95 toy and 1,90 tpy respectively.
The operator used the following equation to calculate the annual heat input Heat Input iMMBM/yf)=1Ummntroiled VOC routed to combustor Iton/yrp•(20o016/ton1/IMW (Ib/Ib-moIN•I3]9.41 scf/Ib-molie(1/VOC mot %1•IHeat Content(Btu/scl)1.11MMBtu/1,000,000
Btu). The operator expressed the values for molecular weight VOC mod%and he. coused in the equation were obtained from the flash gas stream in the ProMax simulation provided in tvalues used appiimtian. The valuused in the equation are es follow: lit Molecular
weight42.T966Ib/Ib-mil, (il) VOC mol%:51.]21377%,(gi) Heat Content: 2392318tu/scf. Using these values, the operators .dated a heat input of 1],839.? MMeto/yr. Since Wsvalue is more conservative than the value maculated above using prescribed methods, it
will be used for permitting purposes.
e. According tothe application emissioss from the storagevessel arerouted M al pipeline h ghthe me ofavapor recovery unit (VRU)during normaloperation Durngv tl downtime, emissions from the storagevessels are routed to enclosed rubstor(s). The
operator hasrWcated the vapor recovery urns are down for 35%of timed ring calendar year. Dunn VRU operation, the operator has quested a control efficency of 100%. During VRU downtime, the operator has requested a 95% control efficiency for the
enclosed combustor(s). Since the contrd devices have different control efficiencies the operator wifl be required to track VRU downtime in conjunction with condensate throughput during VRU downtime In order to demonstrate ongoing compliance. The permit will
contain a VRU downtime tracking condition in conjunction with a process limit. condensate throughput during VRU downtime.
9. The permit will contain two process limits with regards. condensate throughput One Ilmltwill reference total requested condensate throughput (1,6S9,360 barrel/year). The second llmHwilt reference total condense. throughput. during VRU downtime (580,]]6
barrel/year) The lion ton total condensate throughput incorporates all the throughput that occurs while the VRU is operational.. the event the VRu hm less than 35% downtime (i.e.the condense. throughput during VRU downtime n fess than the requested limiN, the
operator should remain InMI-entrance _with the emission limits because the VRU is requesting a 100% control efficiency compared to the 95% control efficiency associated with the enclosed combustorlsl As a result, fess VRU downtime is beneficial both for the
environment and the operator.
10. Ethylbenzene and 224-TMP are the only HAPs below APEN reporting thresholds (Le. 25016/year). As a Km.. the permit wig rot contain emission factors far these HAPP-
11. The NOS for this source was provided on OS/04/202o.Asa result, an updated NOS snot requir.as part of the self -certification requirements Mil. permit
•
12,16. controlled VOC and HAP emission factors In Section O4 aboveare based oh the overall controfefficiency assoca.d with the VRU(100%Central) and enclosed combustor(s) (95%mntrol). However, these emission lectors are rwtthe values that will be in the Notes
to Permit Holder section of the permit. The Noses to Permit Holder in the permit contains two sets of ddidrolled emission factors. The firstset represents controlled emission factors that must be used when emissions are routed to the VRU. Since a 300%contrd efficiency
is applied when emissions are routed tothe VRU, the emission factors for this scenario are all represented as 0.00 lb/bbl. The second tit of emission factors represents controlled emission factors that must be used when emissions are routed to the enclosed combwtoris)
during VRU down... These emission factors represent Me uncontrolled emission factors multiplied by a 95% control efficiency. The controlled emission factors represented in the permit are °Iodated in table in Section 09 above labeled `Controlled Emission Factors
Used In Permit
13. It should he noted that the operator used an outdated-eversionot the tank l -stncil in the Prolffix simulation tocalculate working and breathing emissions for this source. As a result. an updated ProMaxsmulaton using the current version pith. tank loss stencil
as conducted Mr comparative purposes. This updated ProM Imulaton resulted in the following emission factors: (I)VOC:1,033916/bbl,fin) Bentene,090278lb/bbl, lin) Toluene: 0.00379,It/bbl,(iv) Ethy,bemene:8.209E. lb/bbl, iv) Xylem 0.0012616/661, M)n
-.Hxane: 0O2681b/bbl, and. 9)2,2,4-TMP 7.13ESib/bbl: White the VOC, n-Heaane and 2,2,4TMPemission factors from this updated sins [Ion's more conservative than the values calculated by the operator, the In emissions is negligible. For eximple.
requested VOCemissionsusing the updated emission factor are856.15 gsy(urcontrolled)and 14.98 My(controlled).The difference in the resulting emissions does. not Mange the regulatory applicability for this source or the facility as a whole. As a result the operator
provided values were accepted for permitting purposes. - -
14. The operator was provided with a &aft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments.
Session 09-SCC Coding and Emissions Fartors (For Inventory Use Only).
AIRS Point# Process# SCCCode _
c ffi 01 'dittttRltikt i,t44100.
'PVC
Pollutant
1 PINTO
PSOx
NOx
VOC
CO
Benzene
Toluene
Ethy,benzene
X lens
n -Heine
224 TMP
Uncontrolled Emissions Factor Control 96
5.718.93
5.318.4
6238.0
23.89
2.508.01
6.90E-02
9.265,12
2.81E 03
3.26E-02
0.62
1.02E4n
Units
6/1,000 gager. Condensate throughput
6/1,009 gallons Condensate throughput
0 b/S,orm gallons Condensate throughput
0 b/1,000 gallons Condensate throughput
6/1,000 gallons Condensate throughput
.1,000 gallons Condensate throughput
VS 6/1,000 gallons Condensate throughput
b/1,000 gallon Condensate throughput
St 6/1,000 gallon Condensate throughput
AS 6/1,000 gallons Condensate throughput
96 b/1,000 gallons Condensate throughput
va b/1,000 gallons Condensate throughput
3af4 C:\users\hslaught\Desktop\123A0F2\20WFOa95.CM
Storage hnk Regulatory Analysts Worksheet
The regulatory requirements below are determined fazed on requested emissions.
ATTAIHMEXT
1. Are uncontrolled actual em,suons from any criteria pallKantsfrom.la lndtrldual source greater than 1TPV,Pezelatbn a, Pan0.ecuon ll.b.tex
ate lservIce datel prior to ix/30/2nnx and not modified alter 12/31/2002 (See PS Memo 05.01 Definitions 1.11 and1.t4 and Sodlenx for aadMenal guidance on grandfather appllmbllhylx
3. Pre total lad0ty uncontrolled we emlulons greater than STK NM greater than let.TP' or CO emissions greater than 101,, Meplatlan 3, Part a.sedlenll.b.312
VON'PTTAIxaM6NT
I. Pre uncontrolled emisdons.rn any c derh pollutants from thls Individual source griper than 1 IV lReplahon3,Part0.xctbn ll.O.vli
E. Is the construction. Gate Ise.=date, prior to lz/3a/2= ant not modified alter 12/31/[aox 54e P3 Memo 05-01bel.ons1.12and,14 and Sections for addRIonesuldance on vendfatnc appllobtlayl?
Are to1all &arty ilninntrolled VOC emasinna gmaterthan 211,,. 110x greater than STPY or. emissions greaterhan 1.0TPY Illeguletion3.Part6.54ellen0.0.217
c.o.d. PISANI 7.. Part° Section I.GF.G
e6.hr ozone control area or any ozone non -attainment area or attainment/maintenance area ,Re[ulaion 7, Pan n.sedlon l.atl'
1. lath!, storage tank located alt. and gas operations Oat coiled, stofe.or handle hyer.ca or produced water dab mztare beaten at or upstream or a natural gas proeas SP nt l6egula0on'. Part o,Senlon l.a112
3. !at,. storage tank ;noted ata natural Ingp ant(Peen.lon',Part b,sectla Ih6jpllqIce 4. NeS Ms storage tankeentaln h'ne(e.gMasi emissions,Reaumlon T. pan D.sectbn l.G.al'
6. Pre uncontrolled actual emissions., thh storage tank equal. or greater than i tons peryeerv0Cl6eplatlan,Pmb.secdani.D.3.ellh'
Part0. SectPo
llution control Equipment—Prevemtan alreaka[e
Part 0,5etlion L. —Emission Enlmat on Procedurespart I.D—Emissionscontrol Requirements
Part LE —Monitoring
Part 0. Sedlonl,lienordkeapIng and Report.
Wonder limulaVan an u
1. Is IAN storage unk honed at a transmluten/sterage facility?
x. Is storage tank located at an all and gas eepinralinn and prodmmn operation, we0 preductbn fadM', natural imscemp,erwrddbn or nature.. eruadneoeni Mop.. 7. Pan bseamn n.d'
yea
eon
ra 6ar.n ex.' INd:
Pert ,Section H.C.2 -Caotere end Monitoring for Storage Tanks Med with Air Pollution Control Nato. tLs Me controlled storage tanktocated at a web production tedirtu,nature, compressordation.or natural gas donoranu may 1.2020 plant constructed on or alter Idayl.2010 or located at a 6. such that en eddmone contr.led storage vessel h concocted to feu. an anticipated Incr.. m thrn.ma m hydrprocessing erbon home rproduced water meeeaon,rart D.Se.ienll.e.+`m
+ 12 w
source Requires a permit
ontinue -You have Intlica,terl <hes. attainment status. the pmlen slum' arysheet.
entEnue -You have laerl the facllity type on .e pFnled
forage Tank Is not subject to Regulation 7, Pert o,Section IGs- You have Indicated lanity type on project summary sheer.
°mina -You have Indkated the source category on Me Pr.jectsummamshen.
Go to me nip question You have.... facility type on prajectaummarysheet.
SeUR issue,.toparts. Replatien',wrtb.5ectlon. II.66C. Go to the nm guest.
*Source Is subject to all prev,nns of ...flan, Part Sena..v 6[
lathe control. storage tanktocated al a well production lacillty.natural gas compressor statian.or natural gas pro:mine plant constructed on crafter lenuary1.2021ur bola, wu mode,. on or afterlanYary
1. lithe Indlvitlual stomee eWm'jl^4' eeaj@0 ,66a.11nbrnx
x. Does the swap vessel meet anowinga.n",tnbu m saave(dnnvm
2. Was this storage vesulsonaructed, recongruned,or rip pee deli.lons 40 CFe.6o21 after luly la, ss. ea CF R 60.11.,,1'
4. Ones the tank meet the tlellnItion oraoraze wets,' In 60.1110
S. Don the storage vessel store a -.Table organic !load (VOL,' as defined In 60.111b'
S. Dees the 'wrap vesel meet any one of the following additional exemptions:
omen., is not subject NSF5 IM-Thestooge vessel capa]ly Is below the applicable threshold.
Nk A
14a:a
NT:sF4_'
tbal„"'fig
b. The alp tabu], it,tea re'VISO nice albubwlth am Pe 160. 0h,20:o
w]ty is 6reeerMan or equal to 76 M',vn abl eta less than 161 in.,.36L] and stores a llquldw n a maximum true vapor pressurele.11. ls.akPa160.voblbNi
7. trol requIremenN
Don the aorege tank mint either one ofthe following
a. The destge capacIty Is greater than re m'C65 BBL] nan o
The amp p tvsgreaerthen oreq..,to7SM'I'n'a PRP. Men 151m'hm eel)+nd&tares a uwa wan. greater
vapr pressure ehvteemn eryuam 160 kPa but lesstban xx.6kPa'
Sea CM. Part [...art standard. of Pmam,ameter Cnida Mull Natural Gas Prod... TR W.. nand °uMwtlon
2. Was this rage vessel constructed, reconstructed, or modified (see dellMNonsao CPR,60.xl between Augurs 23,2011 and September...Si
1. Ms Mk storage u.6laher September 28,10151
4. Are potential voe emeaaa
bm' fromthelnalvidue.ora.treater versel hn or equal to 6 tans per year'
60.6420,160.64300
6. Is the storage vessetsulaled to and controlled in acondance with re elements forrtorage vc..is 40 CFR Part 60 Suboart6h or 40CPIIPart62 Sub NMI?
lag,..u.ea.,..
[Note; lausNdu .Men to NSPS 00/00 ...emissions ...tons pert' arhOContae appllcabaltyaetermbamn aate,N mnM remain subject a NSPS 0000/0000a por
60.s3651ej121/ho.s36se.lxl awn epos potential Voc emh:lons drop below 6 ,tons eery. 'jaua
nd natural bas production facility that eets either of he 1. Is the storage
a. Aeciimthet pro en� P[ esorswremymcarbon l,quld,'n1 3.766141211 �03 mvmanXeria.
•
b. lad. that processes.unrades rHnns nat
ural Las prior to the poInt at which natural Las enters the natural gas trensmIsslon and storage source category or is.. red tea final end user'163.'e0ej(311'
x. lathe tank located etafadlty that is realer, or
a. Does the tank meet the debrutIon orstorage vessel wIthMe potential for flesh missions.' per 63.761,
S. Is the tanX sublect to nontrul requirements under 46 cF6 Pert 60, Subpart. orSubpart 0000?
Subpart0. General pro ,slon, per 463.7541a)Tables
466.n3 -Moorman[
4..774-Remrdkeepine
PACT Review
PACT ;Wow is required VItegulation does not applyAND II...aisle the nonanalement area. iltryn tank remota both rre-• ad, then review PACT 'a...mu.
Disclaimer
T,a docmrentass. operators won determining epprnolily?nyled m'uvene. or Ma Clear,. act Il:impkmnfineregulalioia, and Axquaiy.`,.Canr nr.V.,.... a a dallaalTend
gw..aMMgr anaNalai1ernbiasmarrim app'oe partawa si,edobaud upo.meb,i+,r91 hatstand a.= Yaw. This *alma, aas alma, araaaaaany tax. raleon.
AvW IawMhir,lgrguvemenlnav mflganfl lye,the even, of any amtt. between u
arg.la,ugeaW]0.wuabM some,aqugeameeleg NAcl. ih impkn.q,m0 rgweliors.
iyenbaComrd.elonrgwatieu, the inguageorlhe shlulemrquhvn woo... Tne ree,nonrraidatoylnquepa suc aerammnencl,..K rah .1,d,,,, i....
O/nfaNe,et' Mendel, oandogyarch ac'musr errga'eroeintal bdmoibccorairgrepwerre,s unit Ma Isms son ArAaand
qualMennbur Corv,aiionA.. ,b, bus bdocumnldme n, es blah legally binding ',u eta. in and olirwt
attiVf
Nd4�
Ova
xAaR-'@
No's, Sxa"
Nph'atik
Nk4a
Nn4.
w.ect summary sheet.
.ubjj« MPS DODO- Go StoMenemoue,tlgee.ntmueaeerminaton&MPS 0000aappliabiny.
o m`the neNnot
e`stleq
storage Tankissubject Ws coma.
Wrap Tank Is not subject MR NN -There are no AMR. remgrements forma at area sources
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
PDC Energy, Inc.
123
A0F2
Sanford 21-29 Pad
History File Edit Date
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per vear
EMISSIONS With Controls (tons per year
POINT
AIRS ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.8
0.8
0.0
0.0
89.3
1,876.6
0.3
120.5
78.3
0.8
0.8
0.0
0.0
17.0
40.9
0.3
25.9
2.5
001 inciuded in previous eoi<.
Previous Permitted Facility total
0.3
0.3
0.0
0.0
82.1
1,875.4
0.0
114.5
78.2
0.3
0.3
0.0
0.0
9.8
39.7
0.0
19.9
2.4
Puna 00i included rn previous for:,;
001
GP10
6 Condensate storage tanks
p 0
r0:0
Covered under poin4002 (20WE0495)
Loadout
00
-
.. 0.0
Covered underpoint 004{20WE0497)
PW tank
0:0
0.0
Covered under point 003:.(20WE0496)
NG Engine Cat G3306NA
-
0.0
0.0
Covered under point 006 (GP02)
NG Engine Gat G3306NA
0.0
0.0
Covered under point 007 (GP02)
NG Engine Generator 500 hp
0.0
0.0
Covered under point 008 (GP02)
Well maintenance / unloading
7.6
0.1
7.6
0.1
No Change - 3114 scf/event x 392 events = 1220.69
Mscf/yr
Stitt
:i`v'y"d1 0493
:ih: (6)400 CIA fixed roof condenza%r.
ntoreme vessels
..,,.
...,. _.
..
,
;
s.1
:
!t"env Sourer
4i`3;F
24)VVE0496
Two f2)400 febi ftxd ..,:,,,,A,,,,,,,,,
water storage vessels
,10
1r,
bV.G
...
.M1.J
,...
..il
:.,
rl.fl-
., (
t.V
'il. {
„' a
6 Ca
\IQ°fl' +JQar�v'e
o : ,
20)M241427
Ii. r..
.: .,
v.l1
E,r S.
,fit
,.,.,
.,
1,O
v,; S ,..
005
20VVE0498.CN
Flaring of netural gas vented ftern one
(1) gas buster during VRU downtime
0.0
-0.0
Cancellation received 11/12/2020. Emissions are --
below APEN reporting thresholds.
A„
etite,01
., ,., .. t.,: „z rr, t;;?', ..,•, I ,.%. „c4d..
g:i7 H4' (rstte ratetC.;, 'uN; da"ti'X03sl3is
s, o
tr.1
',.'I
> "�
18:1
0.4
%:.1
s 9
,.fr
^...0
04
N,,,a 3#a,.. CA...119Hae;.isaod feu compression
.
taE*r0.2
.':. °'0 21.99, 4 oREI, , , i h.r; ..
+0.x707
.
t.C;
...
. ^.?
t tan
^,s
.:....,
5
'd *i
,,.
o.a
New Source - engine used for power generation
GP02
°1.0L, 45',6��,..;7 , �h,',
en.
-,
_
:aaB.Q9
n.r1
,..,
...
_.
0.8
New Source - engine used for power generation
XA
External Combustion Sources
0.3
0.3
3.6
0.1
3.0
0.0
0.3
0.3
3.6
0.1
3.0
0.0
Insignificant Source
XA
Fugitives
0.3
0.0
0.3
0.0
Insignificant Source
XA
Sandtrap Drain Tank
0.8
0.0
0.8
0.0
Insignificant Source
XA
Equipment Blowdowns
1.0
0.0
1.0
0.0
Insignificant Source
FACILITY TOTAL
1.7
1.7
0.0
0.0
161.2
969.8
0.3
244.5
35.9
1.7
1.7
0.0
0.0
17.1
40.1
0.3
30.9
3.4
VOC: iivri Minix,' ;ar' ,e ..:r t MANSP, min Ott)
lgOz: rtto Minor (NANeCR and OP)
CO:: Syr( Minor (OP)
PAPS: Syit Minor n-Hea;_m Totai
Permitted Facility Total
1.4
1.4
0.0
0.0
157.6
967.9
0.0
241.5
35.8
1.4
1.4
0.0
0.0
13.5
38.1
0.0
27.8
3.3
Excludes units exempt from permits/APENs
(4) Change in Permitted Emissions
1.1
1.1
0.0
0.0
3.7
-1.6
0.0
7.9
Modeling not required t,=aced bn fl Chan<3e in
muisslons. Pubcom is required Mrt now syn minor
WilRS Swe being established,
Note 1
Total VOC Facility Emissions (point and fugitive)
(4) Change in Total Permitted VOC emissions (point and fugitive)
40.3
Senility is eligible for GP02 02 beca(dsr° c 90 1p (CC))
and d 45 4py (Pax CS VOC)
Project emissions- less. than 25 tpy (NOtr 8 VOC) and
less than 50 toy (CO)
-1.6
Note 2
Page I oft
Printed 1/11/2021
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIRPOLLU'HON DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name PDC Energy, Inc,
County AIRS I0 123
Plant AIRS ID AOF2
Facility Name SaelOrd 21-29 Pail
Emissions - uncontrolled (Ibs per year
POINT 'PERMIT Description
Formaldehyde
Axtaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224TMP
H2S,
TOTAL Scy)
Previous FACILITY TOTAL -
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP10
5Cord nsa.e Nxzrtc. anu,
<'
•�°.q'
,...rz+
,g=;,.
'.
00
kcmdeui
4
00
PW tank
c c
00 '.
NQE are L.SGu306NR
NG En)ro ULt G3306Nf.
00
NG Enoine Gene IXt hn
y+nv`ie.,i3x.Mii
c r4� ,r
OO.u.vx`
Well maintenance i unloading
13n
0.1
002
20WE0495
Six (6) 400 bbl fixed roof condensate
storage vessels
_
4809
6452
140
2263
43268
118
-
28.6
003
20WE0496
Two (2) 400 bbl fed roof produced water
storage vessels
1604
1866
36
504
1967
,
3.0
004
20WE0497
H drocarbon Liquid Ldut
345
2995
17
N9P'4`7
plaq�tg attptuFgl§aadeAf, r
,`����L
006
GP02
SI RICE Caterpillar G3306NA, 4SRB, 137
HP (site rated), SN R6S02338
766
31.3
29.6
17.7
34.3
0.4
007
GP02
Si RICE Caterpillar G3306NA, 4SRB,137
HP (site rated), SN: G6X03836
766
31.3
29.5
17 7
_
34 30.4
00B
GP02
SI RICE PSI 21.9L, 4SRB, 581 HP, SN:
EZYOF903707
1101.6
1499
1413
BA 9
1644
0.B
009
GP02
Si RICE PSI 21.9L, 4SRB, 581 HP, SN:
EZY0F802898
1101:6
1499
141.3
84.9
164.4
0.6
XA
E#erne' Combustion Sources
0.0
XII .-.
Fugitives
12
12
11
11
13
0.0
XA
Sand rap Drain Tank
9
40
0.0
XA
Equipment slowdowns
4
4
02
1
'19
0.0
TOTAL tpy)
1.9
0.2
0.2
3.5
4.2
0,1
1.4
24.2
0.2
0.1
0.0
0.0
35.9
'otal Reportable e all HAPs where uncontrolled emissions > de minimus values
Red Tod: uncontrolled emiesvms t de mint.
Emissions with controls (Ibs per year
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acroleln
Benzene
Toluene
Ethylbenzene
Xylenes
'n -Hexane
McOH
224T VP
H2S
TOTAL spy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
GP10
6 Condensate storage tanks
0 0 :
Loadout
00
PWtank
00
NG Engine Cat 63305NA
k
0.0
NG EnoCat G3306NA
00
NG.Engine Generator 500 hp .,.,u .6.4
Well ma ntenance / unloading
0.1
002
20WE0495
S. (6) 400 bbl fixed roof condensate
storage vessels
84
113
..
40
757
..
0.5
003
20W E0496
Two (2) 400 bbl food roof produced water
storage vessels
80
93
3'
25
98
0.1
004
Hydrocarbon Liquid Loadout
17
150
0.1
e2eu00xhWxvrE0497
>
jr K.9 �00
006
GP02
SI RICE Caterpillar G3306NA, 4SRB, 137
HP (site rated), SN: R6602338
713.1
G 3
._ ,
.;
,L7
0.4
007
GP02
SI RICE Caterpillar G3306NA, 4SRB, 137
HP (site rated), SN: G6X03836
713:1
31.3
29.5
17.7
34.9
0.4
008
GP02
SI RICE PSI 21.9L, 4SRB, 581 HP, SN:
EZYOF903707
1181.6
149:9
141.3
54.9
164.4
0.8
009
GPM
SI RICE PSI 21.9L, 4SRB, 581 HP,SW
EZYOF802698
1101.6
149.9
141 3
84.9
-
164.4
0.8
XA
External Combustion Sources
0.0
XA
Fugitives
12
1'2
i1
It
13
0.0
XA
Sandtrap Drain Tank
9
40
0.0
XA
Equipment Blowdowns
4
:t
0.2
t
19
0.0
TOTAL tpy)
1.8
0.2
0.2
0.2
0.1
0.0
0.0
0.8
0.2
0.0
0.0
0.0
3.4
2
123A0F2 1/11/2021
COLORADO
Air Pollution Control Division
Deparameni ed PuGL_ Health 6 Envircerme-a
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0496 Issuance:
Date issued:
Issued to:
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
PDC Energy, Inc.
Sanford 21-29 Pad
123/A0F2
NENW SEC 29 T5N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
1
Facility
Equipment
ID
AIRS
point
Equipment Description
Emissions Control
Description
TK-2
003
Two (2) 400 barrel fixed roof produced
water storage vessels connected via liquid
manifold.
Enclosed
Combustor(s)
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
Page 1 of 10
COLORADO
Air Pollution Control Division
Degx3f meat ce Pub L_' Ffealth 6 Ethircrime a
Dedicated to protecting and improving the health and environment of the people of Colorado
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
3. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4. 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
5. 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-2
003
--
0.7
1.0
1.3
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 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 both 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.
6. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
contained in this permit. 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.
7. 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
Pollutants
Equipment
ID
Point
Control Device
Controlled
Page 2 of 10
COLORADO
Air Pollution Control Division
De artmentc P UK: Fieaitt E.rivlrCrVrte,it
Dedicated to protecting and improving the health and environment of the people of Colorado
TK-2
003
Enclosed Combustor(s)
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. 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,
Section II.A.4. )
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK-2
003
produced Water
Throughput
929,000 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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)
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.24; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or
Page 3 of 10
'COLORADO
Air Pollution Control Division
()mailmen! d Pub lr_ Health 6 tworciArne-51
Dedicated to protecting and improving the health and environment of the people of Colorado
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.C2.
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 this point, the owner or operator must follow the most recent operating and
maintenance (O&M) 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
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. This permit replaces the following permits and/or points, which are cancelled upon issuance
of this permit.
Existing Permit
Existing
Number
Emission Point
New Emission Point
Page 4 of 10
COLORADO
Air Pollution Control Division
Department ce Pub Health 6 £nvircru'rien1
Dedicated to protecting and improving the health and environment of the people of Colorado
GP10
123/A0F2/001
123/A0F2/003
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section 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 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.
21. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Facility
Emissions - tons per year
Equipment
AIRS
Equipment
Pollutant
Current
1p
Point
Description
p
Threshold
Permit
Limit
Page 5 of 10
COLORADO
Air Pollution Control Division
Depaivnent o4 Putitr_ Hz l!h b nvirtiome i
Dedicated to protecting and improving the health and environment of the people of Colorado
---
001
Well
Maintenance/
Unloading
NOx
VOC
50
50
17.1
40.1
TK-1
002
Condensate
Storage
Vessels
TK-2
003
Produced
Water
Storage
Vessels
LOAD -1
004
Hydrocarbon
Loadout
ENG-1
006
SI RICE
ENG-2
007
SI RICE
GEN-1
008
SI RICE
GEN-2
009
SI RICE
---
---
Insignificant
Sources
Note: APEN and permit exempt sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
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
Page 6 of 10
COLORADO
Air Pollution Control Division
DE-Aanmer,l cr. Public: Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
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.
By:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Permit for produced water storage vessels at an
oil and gas well production facility.
Page 7 of 10
COLORADO
Air Pollution Control Division
De anrnent of Put.lr_' fieakri 6 Envvcnrne-A
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 forthin 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.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
003
Benzene
71432
1,604
80
Toluene
108883
1,866
93
Ethylbenzene
100414
56
3
Xylenes
1330207
504
25
n -Hexane
110543
1,961
98
Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
1.32x10-3
1.32x10-3
TNRCC
CO
2.63x10-3
2.63x10-3
VOC
4.284x10-2
2.142x10-3
Flash Liberation
Analysis and EPA
Tanks 4.09d
71432
Benzene
1.726x10-3
8.631x10-5
108883
Toluene
2.009x10-3
1.004x10-4
Page 8 of 10
COLORADO
Air Pollution Control Division
De,Aaarnent 0 Public Flea lrtl b i_rporo 1me A
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
1330207
Xylene
5.426x10-4
2.713x10-5
110543
n -Hexane
2.111x10-3
1.055x10-4
Note:
The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific emission
factors for this source were developed using flash liberation analysis and EPA Tanks 4.09d. The flash liberation
analysis is based on a pressurized produced water sample that was obtained from the outlet of the three-
phase separator for the Sanford 32N -30B -M well on March 26, 2020. The sample temperature and pressure are
60°F and 388 psig respectively. The sample was flashed to ambient conditions of 12.2 psia and 72°F. The
weight % values, molecular weight (28.7966 lb/lbmol) and gas -to -water ratio (5.5 scf/bbl) established through
the flash liberation analysis are used in conjunction with the EPA Emission Inventory Improvement Program
Publication: Volume II, Chapter 10 - Displacement Equation (10.4-3) to calculate the flash portion of the
emission factors. The working and breathing portion of the emission factors were developed using EPA Tanks
4.09d. The simulation uses Denver for the location basis and a mixture of 95% water and 5% crude oil (RVP 10)
for the liquid basis. The simulation assumes 1/2 of the total throughput flows through each of the storage
vessels. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138
lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a GOR
of 11.624 scf/bbl and heat content of 822.6412 Btu/scf. Actual emissions are calculated by multiplying the
emission factors in the table above by the total produced water throughput.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer- to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, n -Hexane Et Total HAP
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC Et NOx
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
Page 9 of 10
!COLORADO
Air Pollution Control Division
Det.,aftrrent of RuGI✓ Health Fs trporcroie-,1
Dedicated to protecting and improving the health and environment of the people of Colorado
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 Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
For Division Use Only
Harrison Slaughter
430833
5/4/2020a
10/20/2020 -
Section 01- Facility Information
Company Name: PDC Energy, inc.
County AIRS ID: 123
Plant AIRS ID: A0F2
Facility Name: Sanford 21-29 Pad
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad -
What industry segment .Oil & Nataral Gas Production & Processing
is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? Ozone (NOx & VOC)
.5719 quadn:' a SN, Ran e 6EW
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?
Acton
Engineering
Remarks
003
Storage Tank -
TK-2
Yes
20WE0496.
1
Yes
Permit Initial
Issuance'
Quadrant
Section
Township
Range
NENW::
29
5N
66
Section 03 - Description of Project
PDC Energy, Inc. (PDC) submitted a permit application requesting permit coverage for several new sources at a well production facility located in the ozone non-
attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon
liquid loadout, separator venting, and engines. The engines are requesting GP02 coverage. This analysis only evaluates the produced water storage vessels.
This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 3, Part A, Section II.B.3.a)'.Additionally,
>;
the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC Regulation
3, Part B, Section II.D.2.a.). It should be noted that issuance of this permit serves to cancel the GP10 coverage for this source.
Public comment is required because new synthetic minor limits are being established with this application.
Sections 04, 05 &
06 - For Division Use Only -
Section 04 - Public Comment Requirements
Is Public Comment Required?
Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremer
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: 502
Prevention of Significant Deterioration (PSD) DODD
Title V Operating Permits (OP) i DODD
Non -Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes, indicate programs and which pollutants: SO2
Prevention of Significant Deterioration (PSD) DODO
Title V Operating Permits (OP) 00000
Non -Attainment New Source Review (NANSR)
- No
Yes
NOx CO VOC.
El ❑'
No -
NOx ^- CO� VOC
❑ ❑
PM2.5 PM10 TSP HAPs
- ❑ ❑
❑ DOD
PM2.5 PM10 TSP HAPs
❑ ❑
000
Storage?ank(s) Errfc,Las Inventory
Settbn u1-ndminbt•me Information
IFatlliry rlRs lO:
St age Tank Liquld
Detailed Emissions llnit
Emission tso.'Mke
Requested Overall VOC&HAP Contra
Limited Process Parameter
Section 00 -Process. Rea Informatlen for Embsiam Estimates
P.m, Emissions -St
orage
Actual Throughput
!Requested Permit Limit Throughput.
Potential to Emit IPTEl madernaerbraugFput-
&monthly EmIsMana Cembestion oevlml•1
Heat content of werte gas=
Volume of BL of llqulds produced=
dual heat antemitted
t content of waste gas routed to mmbustlon device=
Requested beet content ai waste gas routed to combustion device=
.v_- scf/bbl
Potential to Emit (PTE) Feat content of waste gas routed to combustion device.
Centro, Dew.
9arrels Mbll Perlmer
Requested Monthly Throu.Put=
NMI, per year
3.30,1 NIMBI, per Year
Section 04- Emissions rectors Methodoloalea
Flash Masao.
NON
Thoolhumt
GOP/GWR
b/Ib-mol
bbl/year
cf/bM
mass fraction MI
Emission Factorlih/bMll
Emissions pbs/yearl
Hellum
co z
07.0
27.45670
Isobutone
mbuksene
opentene
mpentene
cyclopentane
42600
Maohmane
Other Immo.
methylry wane
224-1MP
EthyIlk ensre
Wen.
Total
VOC Wt.
Working 0 bb :
EPA Tan. Throughput
_-:.z__.
bbl/rear
Pona•ne
400 Barrel Tank EmIsslons lib./Veep
..,...,.r Pacor libOMO
VCC
Borden.
1.43E-05
Toluene
EtlMbem enn
xvlene
n-HeYane
S.,
0
3,24iMP
ono
4u_.HIO
gogoincoan..mng„030:9S.gingdioN ffil:.golk.
Will Mls storage tank emit flash emisalor,
2v.o_n Barrels Mill Per month
For Reference &
635.. FVP10
voc
av0 Emission
or bbl 400 Mat W&B TotalPTE Ib/yr
251.02 20L02 2.36,04 432E -0E 10.07 tpy
11.32453711 11324.711 2.93E-05 L74E-03 1617.50 lbhr 13.17755071 1317755871 5.40,05 2,63-03 1852.22 0307646055 aIbhr0.307641.65 1 bO lb/yr
3.55907.5 3.550437255 0.20E-00 5.42E -0a 00042Ib/yr
13.04502552 1334502552 3.55505 213E-03 1377.57 lb/yr
Pollutant
Pollutant
Pollutant
Uncontrolled
Controlled
OMMuc•d WaarThrmrgnpal
Uncontrolled
Unseasoned
Hb/Mmnu)
Ilb/MMacry
Emission Foe. Solatee
mks. n or Mu roe
talon 05- Emisalons Inventory,
Criteria Pollutants
Pomo., Emit ti
Uncontrolled
ltonehmrl
tal
Uncontrolled Ac Emissions
G ttrolled
{m heerl Rom/rem!
Permit Limits
Uncontrolled Controlled
lamhmr) (mm/veari
q Monthly llmlts
Controlled
OM/month)
VOC
CO
008
,
I,.
..0].
I.01.
I.??n
-
tune5
Haardous Mr Pollute.
Potentlal to Emit
Uncontrolled
llba/yearl
Actual Emission
Uncontrolled
ntrolled Controlled
0.1,1 Ilah.
Requested Permit Llmlts
Uncontrolled Controlled
llbehearl Ubs/Yearl
Fthylbemene
&vlane
TM TM.
..j
2100
0.0.
n..O
0.00
OW
,..0
2,1
C\11seraMdanghtWesktop\1233052\20WE0496.CP1
Storage I ) Emissions troosomiiv
Section... ulato Sunwia Ana Al
Regulation 3, Parts A,B
Regulation 7, Part O,Section C
Regulation 7, Part D.Secgon
Pegulatlon 7. Part E,Section
Peguladon T, PartOsecgon ll.ep.a.11l
PegulatIon 7, Part D,Section II CA ahiil
Re.datlen S, Part A, .Ps subpart Kb
Regulation 6, Part A, I,1SPS5ul,part 0000
NEPS subpart 0000a
Regulation S, Part E. MAR Subpart NH
(See ragulatervapplic6ilhy worksheet., detailed analymh)
Section 0-1- !Ala, and Pariodle Semolina and Testing Requirements
For s,r crude s does ecom a use state . ssons factorsestimate emissions,
If yes, are the uncontrolled actual or regiuee2d einisslo. for arrude all tank estimated to be greater than prequel to 20 tons VOC per year OR are the uncontrolled actual or requested emissions for a
condensate storage tank be n or al BD tpyh
If yes, the perm. will contain ane nitral Compliancea'testing urequhementm develop aelte spec,. emissions factor based on guidelines In P5 Memo 1.03.
I s and if there are flash emissions, are the amlsslons radars based an a ':.ssurize Ilquld sample must he ell. being permitted (for produced water tanks, a
analysis),Thls sample should he consitl red represenntive whl=h generallyme.ns site-spedflc a. collect.
hoPrithln one year of the don receiedndate.Noufe ,ifthe facility h.: not been modified (e.g., no new wells brought omlinel, then it maybe appropriate. Use en
older cigc If no, me permit acetate mntaie an"I U. compllence" testing regolrementto develop a site specific emissions factor based on gulaelnea In PS Memo 1403.
Does* company request a control eefficiency greater than 93zfor a flare or mmbushon device,
yes, tha permit will contain Initial and periodic. compliance test... accordance with PS Menlo 20.02
SectTechnical Analysis Notes
Eased on the ',PEN, fourteen ( wells produce to fIls fee.. Please ereifm:he APN totted on 0S/06120?0 fora,t of the ames and AP. mcnbers AcoardIngMCOs ace oE,Eoismoszruoc,mos aacw.r0 bd
.fdJanuary 2020erdeganprodUctnn between January and February 2010 Eleven pc .01, produce rom t:e Ihlabramormahon Two well, attt'z feats produce fro, the Carlf,le-Codell.PortFass PormatIonsonhe
tmell-Pert HaysTormaore T. sample used westablishnbe rash pardon of the emIssfor factors *as ahlafned from the outlet of me three oham fenarator for the Sanford 32h1-303, well on helarch 26, 2020 Thfs sampIT has cot.
"neapp rayon subm.. Add o na r this .mpla was obtained after all theat rfn rack, began productfor, and no new was Nueadded
flshporPon Or the em ,Sed there n .rtuf..phnp.
Z. In order to develop the, ash portion oftte en f cbrir the operator conducted a 3/2 /. _ -
conditions of366 este and 6 yeas. drafent cond.,.o UT osfa end 72,
Inventory Improvement Program PublIcatIon,Voltone Chapter 10.- Ulsolacernent( o 3,to ons available
.3 Emsspsoon, htorg.Wsiels rrcltide flash emssfonan addition tawoldng and breaMfng emissions. Az; res 1, the operator 5 required maculate r zvo,g hrea! g emls,onzazsciiated M.he atorae vessels include this pone., Oi
em( the onfactor, The w ddt. the woflg and hneathing factors rand sx all OR10)for
Ircluldb.sf, The waters n 6ythe operator n heEPA Tan se, he wa E hU m
Antulnes Constants:O R s r,)61P115O2g6and fli Ic 13 .The aka VP 10 p specified using a vapor molecufar iivoots: so ISPbrnd, a liquid moleclalar weightp em bob 7.1,3/gallon ,r
ofegul m d L was ionnpd AP 4, ] f d hy n
3Vr aide.. match wq z for ter pot, ctude clitinrefference handbook$ and APA,Moperator assumho trmt 1/2 of the ,atal Irquid tNaughpurpasses Mrough each storage r g normal operation.
situlation are ave..vensemono '
operamrs assume the hydrocarbon liquid compotlont Mter is composer of a standard gasoline ne Is,. vs;z fed Inthe EPA Tanks Chemical Database. For comp.tive purposes, ayes, Tanks am ench ,,asi onusins
is%ga�llne avaloaross%water(MIW=1g{usbnhmw, Amore. 6e,f'S Itornsulted VOC emission factor of 0.043211,/blol.rna remainfng a.dfrwn
'atonN ahoy.. m - ane
operator, f f kng d E d I
wate42.F.aPoe.[hf,he use p ter rather
e. ud usd ecdse In E. EPreferencel,ten u
AP4 F of wodse ereidtor eemethe rep. xbohiqunntual sixav doted .(esa ne 's 'serym« opera.,
.lee were deemed rep tetr ors diissEE,o p. virtu gpu. purposes.
5. Ethybenzene and 22 rcth_ony HAP, below ADEN repo. nneslm'u.1 =.2.5 ( ctrl Axa..zut, thc pe,,,,hffhnu, Ton .msmfcr=.sf mdse HAps.
6.The NOS for this wurce was proh.ded on0-5/04/2,20. As'exusulh as part°,
N
',dem. storage usels and produced wa mrageve ens i.e OD) from
orderto deem,. app abnrty. .stale. aria ,r; act«. summed together
nth enypre rramal rag are. acove zp« g. mrez t the permit far each e:,ua nam emissfon Ihnfts and em allon rat r«nOaard co.
S. Sin, the conden.te prase vessels yet condensate stonag
vessels arm the highest emitting sou.ue. As a molt, pilat light amis.. hccoun,ed rot wrtf,e arfulysi, for .e con. rsa,e stornge(et 2o.v.ti,MC v PA far pilot Ifghtaculahons,.
9 oral m per edit opacity observations areaddrms. enn OWplan A=a s ttu nem, does not cents
.Typmm.l,eae n�a t3 ea .age
55:<.frobct.H aeenM,.3 at2c., wg.R eat contest tit r �a dad
ea f out tr u/yr7 1(„,T..btilv=arl kss sf/bblW0-.w0,o /,AMzc] 1a22s 12 MABtuil. II
the actua NOT an mzslons would ated. ato24 py d roy esPeaxey M
The the hgequanor, acu to a annual Input I1,...,xl [Uncontrolled ofton/v,N20011b/ton/M Ib/smor))13,91 xf/ mo]hfINOC root l'1Hezt ca,tent
scorn f_h'b�at od s water sample ed in Me application
�1 values
{e4 d In MI, C®0U.03re7.ghedpe eased mar m/llecua'nve'gc used in were es vast cbe
come...tanth'q V ed aol ow(p Molecular eb(Ie maij) .nf) 126tu/sF Ee yy. d.lnshaiu'z
han the value a cWated:abpve evned metF.x1 content ei. Usngm rzz ohs ape a- daFeafn p03 ram more
amrwazpovd v alts a draft. p .and APEN'ti m to o me tTh open s=lum both. documents and
/a -this onh apep:sto and.mam/wa. oii smmpa v.*.
section 09 -5CC main ane Emissions Factors IFerinvenmry ui. onlyt
AIRS Ppmtx
Process,
01
.y
palvu5d mode are Chu,. cv cs I)
z and MW: oh/bmo:uzgthis data. the annuaffi uat
s b/bb) ,> b,/yea)/(so /Ibmo) 3 d/Ibn ) ( E .V.11/(1.000.000 PluNMSton S
cl en:
Ew(ypo
Uncontrolled
Pollutant Factor Central% Units
--M /1,00gahpns Produced Water mrouahppt
h/1p00 gallons Produced Water throughput
SOx6/1,00¢ gallon produced Watertbreugnput
6/1.000 gallons Pmdu=m watertwoughput
VOL 16/1,000 gallons Pr.d.ed Water throughput
CO C.e/1,O throughput
AIM Produced Water roughput
Toluene - - /1,000 gallons Produced WaMr throughput
Ethylbemene MOM
Xylene
b/1,Oo¢ gallons
Produced
ware. mrWsnaUt
6/1,000 gallons Produced Water throughput
224 TIP a.:.fi..-9. 5 b/loan gallons Produced Water throughput
3a. C\Users\sslaught\l'.I top\123AOtx\20WE0496.a1
Storage Tank Regulatory Analysis Worksheet
Theregulatory requirements below ore determined hosed on requested emissions.
ATTAINMENT
� aertartnnzmlaegu of nIl.DfaR
3. Are total facIlity uncontrolled VOC emissions greater than 5,1. N. greater tn. o TPV or CO emissons veatertM1 I on, part B,5ect. II.D.117
NON -ATTAINMENT
1. Are 1. Are uncontrmnW emlssiouirom any ulterta plutaniz from this indlvWwlwura greater than fTW lAeguNNon 3. P.Ra.senlon ri.0:lal)
2. Produced Water Tanks have no eranalathuing Pmvblmns
3. Are total fad@vueenntrolled
Vry Ions greater than 2TPY. Noe greater khan 511, or CO emranoneereaterthan 10,1 lneeuledon 3, part B,sntlon 4.018
1. is thls storage tank looted In the ahr none control area. or any mane non.attalnment area far analnment/malntenance area laeeulatlbn ). Part D, Seatlonlnll)
handle FWroarbon'Ilqulas or produced valet AND that are located at or upstream ofa natural gas prncesslne plant tnegulatlon 7. Part O. searon
3. 1st. storage tank lnatedrata natural.gat p Ing plant
g la bn).Parto,seatlnnl:clt
5. Does this storage tenk e.hlhlt flat h,e.g.slodngnen stabllizetl liquids, emissions lnegulatlon yip o, sEctwn I.N11)
Xes1z`d.,
Nall...an LE —Walter.
Part 0, Sett., Recnrelkeeping and Pep...
part D, Section I.C.I.a and I3 —Gene. Requirements tor AlrPollutlan Control EquIpmea —Prevent,. er,mee
1. Is Ms storage tan.1<looted at a n/std 2. Is We storage taek. pc,ted et en and gas exploration and prodisalon h.a operation well p. union f.Mk?, natural,. compresor mural gas processing plans'(Peculation ), part D,Sectlmn Usti)
3. Does thksterage tank have a find roof 1PagulatIon 7, Part D.5ettmn
Part 0, sectIon II.C.3-liecordNeepIngliepurrements
5. Do. the storage tank contalntlnlestablIlved.11qulds Illegulation 7. Part 0.5ectIon
Part Cy section ll.e.z-Capture and Montorme for storage Tank..6 with alr Pallutlon Control Equipment
7. 1,20.2.1. such thatanadd,nonala.rolledstoragevesselIsamnaruneatoten!.ananticpatedIncrearelnthroughput of hydrocarbonliquidsorproducedwaterl g lon).Part1).5e[Innric<,xm, dnnnraNerlanEe I
vessel capacity greater than or equal. 75cuhlc mete,. Iml['4n BM 145.st5.l1ob1.11)
2. Dyeable storage vessel meet the followIng exemption In 60.111h111417
a. Ones the vessel bas.a dole opacity less than or
m'[-10.000 Bec] used forpetroleum'. or condensate stored. processed. or treated prior to cuamay transfer' as donned In 60.1111)
3. Was this storage vessel construnedreconstructed, or modllleaulsete dennillmns aO Cfe.60.11 eller July 23.19.140M 6a110I.1)
5. Ewes tne storage vessel store a .volatIle Id IVOI'x ,
6. storage vessel meet any one of [be ollowlus atltlitIonal mruptIons:
a. Is the storage wasal pressurn e m.eNP,IP..)pNland wilhout omlsslonsto the atmosphere lk0.'uObIaIPllb or
b. The design capacIty greater than or equals 15fm',955 BBL] and stores. Uvula. with a malmum true vapor pressoe'less than 3.s 0,5o.nollih1l); or
c. The ciesly, capadtv is greater than requal to)5M'[-4n BBL] but lessthan 151 m'['3St, BBL] and stores a llqula with a magnum true vapor pressure. less than 55;01,60.110b1W
owes
Na¢hYy�"a'+
Source Reoulres an MEN. Go to the nod question
cunt'''. have Indicated the fenny type n the project summary sheet.
Sourcek subject in pamnl.O.0n',Part D. Sections HAS.. Go to the nut qumion
soureekwblea toall provlxlons of neNbtIon ), Pan D. SenIon ll, 5uuxealansn ac
Storage Tank is not subject Nets rcl.The storage vessel capaaty is slow the appllnblethre,,,e,,
1. Is tills storage vessel looted al a facIlity.the onshore oil antl natural gas pFoduttlan segment.natural eas procesilng seementor natural zastrensmIssion and storage segment ettbe Industry',
3. Wes this rtorage vessel constructed, mtructed,nr modified (see aellnitlonx'40Cfn,6a.E)afterSeptereberle,2015)
ContInue•Vou have Indkated the source catego,on the Proled Summary shed.
54owe 'ran. net me, Nsps coon- Do to the nutgones commue dae,,Tdeemn of Nsps Doeo pp y
4am°
mai3.g `ark,
Mete: It a storage vessel Is Revloushrdetertnrneel,.yeato FISP55P000t0000aau.m Emissions above tons prvoa,voc en the apwiabbmdna,mmaunn ate,[ Fab remagnm Iectml�npso no/oo par
2Vs
s0.a3ss1e1[605asse1o1121B even potent., ntmi Vocemesions dp r rook stmn Pmyeag
and Go acrikles
1. ktha tanklocated . an°Wand natural gas pro... [.01[1, ,c meets elf., of the fonowing[Marla:
a. ',facility that processes, upgmdesoratnres hydrocarbon Mgmdxrl63.,601a1un:on
h. A bold, that processes,grades stn. oral gas prlorto the pint m widcM1 natural east enters the natural ostranxmisdon and storage source category or lsdellvered to a Flnal end user'163a60[a1p11)
z. Is the tank located at a radllrynab malod or HAsay
nn orstorage.5551With the petentlalfor flash emissieni'sper 617
5 Is the ta5, sub,ect to control repulrements under 40 CFR Part 60.Subtlart orsubpart cool,
Subpart A General provisions per 64(a)Ta le
4.03.756 ElnIssions C antral Standards
463.775 • Report.
aarr mill,. Is required g...Non 7 does not applyanD nu. cots'sin th. nonaminm.etarea. If the tank men both afmaa, teen rolImrPacT requbemenn.
Disclaimer
Tdls documenl;masts operators wilh delerminina appbcabllityofcart. 'ag b, pe. of Me Clean Air Act ils implemenunp regulations, met a AN Qusliy Cont. Commission reg.., This aocumenl is not
rule orregolekon, end Ilse naryaia ifc,lairss may rim apply fo aparecul, Ave Eon daces upon the ixyvlarellEElsand arc ances,ibis document does no change, suds.,e/of any law, regulation,
olhalepalry binding requiiemenl anaic nallegalrynimceable. In ibeevenf ofany cmnicrdehveen Yoe lanaueaa of tM's document and Me languege m.e clean ail Ag. ds implemnling regulations,
end.umiy con rread. may,,M1ould,•en,can'ia'Mended.
eat mw�r�n urns,.eq�ir rarenkrae+ial.. �owr�egw �ma am[ the ta-me mud clean arAden ,z1
Quality Control campus fauklivan Sul mlcladcurnenlOces not establish legally binding, requirements in an alfaelf.
Storage Tank is not suelea Mph HIV -There are noM UNN requirements for tanks at mammas
COLORADO
Air Pollution Control Division
Depaame+lf ef. Ruble Health 6 Envrrcnme‘a
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0497
Date issued:
Issuance:
Issued to: PDC Energy, Inc.
Facility Name: Sanford 21-29 Pad
Plant AIRS ID: 123/A0F2
Physical Location: NENW SEC 29 T5N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
1
Equipment
ID'
AIRS '
Point
Equipment Description
Emissions Control
Description
LOAD -1
004 '
Hydrocarbon liquid loadout from
storage vessels to tank trucks using
submerged fill.
Enclosed Combustor(s)
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
Page 1 of 11
COLORADO
Air Pollution Control Division
tnent ea!' Pt,Glr- Ffeala 6 Enviturlircle, A
Dedicated to protecting and improving the health and environment of the people of Colorado
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
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:
Equipment ID
AIRS
Point
Tons per Year
Emission
Emission
Type
NO :,
VOC
CO
LOAD -1
004
-
-
4.9
---
Point
Note: See "Notes to Permit Holder" for information on emissionfactors 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 both 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 calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
contained in this permit. 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.)
Page 2 of 11
1�
COLORADO
/lair Pollution Control Division
Department a' Rub b_' Flee lrh b Tnvinxurieem
Dedicated to protecting and improving the health and environment of the people of Colorado
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
LOAD -1
004
Enclosed Combustor(s)
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 rate must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part
B, Section II.A.4)
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
LOAD -1
004
Hydrocarbon Liquid
Loaded
829,680 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelvemonths' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution
control equipment. Compliance with Section II.C.5. must be achieved in accordance with the
following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal
Page 3 of 11
(COLORADO
I Air Pollution Control Division
De:Mr:Melt a Publot fievsh 6 _r,N401 1E -A
Dedicated to protecting and improving the health and environment of the people of Colorado
to 5,000 barrels per year on a rolling 12 -month basis must control emissions from
loadout upon exceeding the loadout threshold.
11. Storage tanks must operate without venting at all times during loadout. (Regulation Number
7, Part D, Section II.C.5.a.(ii))
12. The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport
vehicles and to route the vapors to the storage tank or air pollution control
equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless
loadout occurs less frequently, then as often as loadout is occurring.
13. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect
the facility within 24 hours after loadout to confirm that all storage tank thief hatches
(or other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
14. The owner or operator must retain the records required by Regulation Number 7, Part D,
Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division
upon request.
Page 4 of 11
COLORADO
Air Pollution Control Division
L%eaBCi�tYe i e,? PuGlic Health 6 Ermrcevnera
Dedicated to protecting and improving the health and environment of the people of Colorado
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution,
required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
15. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oit 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 a MAINTENANCE REQUIREMENTS
17. Upon startup of this point, 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 your 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
18. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. This permit replaces the following permits and/or points, which are cancelled upon issuance
of this permit.
Page 5 of 11
COLORADO
Air Pollution Control Division
Deaarurreni E ' PLINK: Health 6 Erl.YirVlJYIP1'i
Dedicated to protecting and improving the health and environment of the people of Colorado
Existing Permit
Number
Existing
Emission Point
New Emission Point
GP10
123/A0F2/001
123/A0F2/004
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section 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 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.
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.
22. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, Section VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Page 6 of 11
COLORADO
Air Pollution Control Division
De'a'4ritrent 6' Qubk Fiealril 6 .rhtreriment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
IDThreshold
AIRS
Point
Equipment
Description
Pollutant
Emissions - tons per year
Current
Permit
Limit
---
001
Well
Maintenance/
Unloading
NOx
VOC
50
50
17.1
40.1
TK-1
002
Condensate
Storage
Vessels
TK-2
003
Produced
Water
Storage
Vessels
LOAD -1
004
Hydrocarbon
Loadout
ENG-1
006
SI RICE
ENG-2
007
SI RICE
GEN-1
008
SI RICE
GEN-2
009
SI RICE
---
___
Insignificant
Sources
lote: APEN and permit exempt sources do not have permit limits. However. the PTE of t
hese sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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
Page 7 of 11
COLORADO
Air Pollution Control Division
I C�..snme d a PuOt: tres rli 6 ErNUixvnee-A
Dedicated to protecting and improving the health and environment of the people of Colorado
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
25. 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.
26. 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.
27. 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 authorizationby 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
28. 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.
29. 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:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Page 8 of 11
COLORADO
Air Pollution Control Division
Devartt e,a CA Put14 Health Er Enytruntnent
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit for hydrocarbon liquid loadout at an oil
and gas well production facility.
Page 9 of 11
'COLORADO
Air Pollution Control Division
teal a' PuGlr_' Ffealth 6 a percrvne'A
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-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions`
(Ib/yr)
004
Benzene
71432
345
17
n -Hexane
110543
2,995
150
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 004:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
VOC
2.36x10-'
1.18x102
CDPHE PS Memo 14-02
Benzene
71432
4.16x10-4
2.08x10-5
n -Hexane
110543
3.61x10-3
1.805x10-4
Page 10 of 11
COLORADO
Air Pollution Control Division
Department ee Hearth 6 GrioB�rlYrlt'^'el
Dedicated to protecting and improving the health and environment of the people of Colorado
Note: The controlled emissions factors for this point are based on the enclosed combustor(s) control
efficiency of 95%. The VOC and HAP emission factors reflect the state default emission factors listed in
PS Memo 14-02 for condensate loadout. Actual emissions are calculated by multiplying the emission
factors in the table above by the total hydrocarbon liquid throughput
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 facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, NOx, CO, n -Hexane EE Total HAP
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC a NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63:1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting, Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer:
Package #:
Received Date:,
Review Start Date:
For Division Use Only
Harrison Slaughter
430833
5/4/2020
10/20/2020
Section 01- Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: A0F2
Facility Name: -Sanford 21-29 Pad
Physical
Address/Location:
County:
Type of Facility: Exploration & Production Well Pad
What industry segmentLOil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area?
If yes, for what pollutant?
FSENW t'ualdrare of Ssection, 29, Township 5N, Range 66W
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
004
-
Liquid Loading
LOAD -1 ,
Yes
20WE0497
1
Yes
Permit Initial
Issuance
Yes
Ozone (NOx & VOC)
Quadrant
Section
Township I Range
NENW
29
5N L 66
Section 03 - Description of Project
PDC Energy, Inc. (PDO submitted a permit application requesting permit coverage for several new sources at a well production facility located in the ozone non -
attainment area. With this application, the operator is requesting permit coverage for condensate storage vessels, produced water storage vessels, hydrocarbon
liquid loadout, separator venting, and engines: The engines are requesting GPO2 coverage. This analysis only evaluates the hydrocarbon liquid loadout source.
>This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy (CO AQCC Regulation 3, Part A, Section 11.B.3.a.). Additionally,
the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy (CO AQCC Regulation
3, Part B, Section II.D.2-a.). It should be noted that issuance of this permit serves to cancel the GP1O coverage for this source.
Public comment is required because new synthetic minor limits are being established with this application.
Sections 04, 05 &
06 - for Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 -Ambient Air Impact Analysis Requiremer
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
Prevention of Significant Deterioration (PSD) 000200
Title V Operating Permits (OP) . ❑ o 0
Non -Attainment New Source Review (NANSR) ❑'
Is this stationary source a major source? No
VOC
0
❑'
VOC
❑
0
PM2.5 PM10 TSP HAPs
❑ 000
PM2.5 PM10 TSP HAPs
❑
❑ 000
-
If yes, indicate programs and which pollutants: SO2 NOx CO
Prevention of Significant Deterioration (PSD) 00000
Title V Operating Permits (OP) ❑ ❑ ❑
Non -Attainment New Source Review (NANSR) 0
Hydrocarbon Loadout Emissions Inventory,
Section 01 -Administrative Information
Facility AIRS ID:
123
County
A0F2
Plant
004
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Hydrocarbon liquid l d utfro�mst ragevess 1 to tank trucks usingsubmerged fill
Emission Control Device Enclosed Combustor(s).
Description:
Is this loadout controlled?
Requested Overall VOC & HAP Control Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Hydrocarbon Loadout
Actual Volume Loaded=
'Requested Permit Limit Throughput =
Potential to Emit (PTE) Volume Loaded =
Yes
95
69139e Barrels (hhl( per year
829,680' Barrels (hhl) per year
829,680, Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Actual Volume of waste gas emitted per year =
Requested Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2392.31: Btu/scf
._- scr/year
3007360 scf/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Requested Monthly Throughput= 70466 Barrels (bbl) per month
5,995.€3 MMBTU per year
7,194.54 MMBTU per year
7,194.54 MMBTU per year
Control Device
Number of combustors (i.e. pilot lights):
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
2
15.6 scfh
1136 Btu/scf
0.27 MMscf/yr
410.5 MMBTU/yr
Section 04 -Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate emissions?
Does the hydrocarbon liquid loading operation utilize submerged fill?
YesS
Yes
ult emissions factorsmaybe used to estimate emissions.
Emission Factors
Hydrocarbon Loadout
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Volume Loaded)
(Volume Loaded)
VOC
2.36E-01
1.18E-i
Sopdensate Loadout State E.F.
' tl°adout State E.F.
sate Loadout State E.F.
Benzene
4.i`u E - u^4
2.080E-05
Toluene
0.00E++';;;
0.00E+00
Ethylbenzene
0.00£"=00
0.00E+00
Xylene
O.00E:U0
O.COE+00
n-Hezane
3.61E-03
1.3050E-04
224 TMP
0.00E: CO
0.00E+00
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (Ib/hbl)
(waste heat combusted)
(Volume Loaded)
PM10
0.0075
5.46E-05
-=able 2.4-2(PM10/PM.2,5J
av ;1:4-2(PM10/PM.2.5} -,-
.4-2(50x)
missions Guidance {NO8)
emissions Guidance (CO)
PM2.5
0.0075
ii.46E
SO x
0.0006
5.10E-06
NO
0.1380
'-.20E-03'
CO
0.2755
2.39£-03
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
IIb/MMBtu) (Ib/MMscf)
(Waste Heat Combusted)
(Pilot Gas
Throughput)
PMl0
0.0075
8.4643
1.4-2(PM10/PM.Z 'E
p].4-2(PM10/PM
AP able 1.4-2(50x)
•P-42 Chapter 13.5 Industnal �.^---
_q
PM2.5
0.0075
8.4643
SO x
0.0006
0.6682
NOx
0.0680
77.2480
VOC
0.0054
6,1255
bie .4-2 (VOC)
er 13,51ndustrial
CO
0.3100
352.1600
2 of
C:\Users\hslaught\Desktop\123A0F2\20WE0497.CP1
Hydrocarbon Loadout Emissions Inventory .
Section OS - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/yearl
Requested Permit Limits
Ummntrolled Controlled
(tans/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
303
NOx
VOC
CO
0.933
0.02
0.62
0.0^a
0.03
0.03
0:92
0.02
0.033
0.03
-
0.92
0.00
9.07
0.09
0.99
..
':_x.51
0.42
0.42
9,21
2.31
23
-7.50
31.505°7
4.02
97.311
2.20
,3
_.0
6.03.
0.37
1.94
1212
177
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
Ohs/Year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year): (Ibs/year)
Requested Permit Umits
Uncontrolled Controlled
fibs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
XYlene
n -Hexane
224 TMP
325.15
337.62
1223
U.5.15
17,23
0.v_
0.00
aco
O.00
0.90
+.90
0.60
0.00
0.00
0.4"0
....
0.00
0.00
0.00
9.00
..
2495.95
124:80
1;9214
949.76
.....;...
0.00
0.00
0.990
DM
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
c_ requiresa permit
Regulation 7Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis
Ocar tran hqu[22 loadout £aurce is suble=t to Regulation 7 Part D Section ii.C.5.
Section 07- Initial and Periodic Sampling and Testing Requirements
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. Tfie standard approach to calculating the heat input rate i ginti i the combustion of loadout waste gas is as follow when using the state default emission factors for condensate loadout:
Heat Input (MMBtu/yr) _ (81.586 ton/yearr(2000 1b/ton)/(65 1b/Ibmolr(379 scf/Ibmol)/(1,000,000 scf/MMscf)'(2255 MMBtu/NiMscf) = 2,145.4 MMBtu/year. Using this value, the actual NOx and CO emissions would be calculated at 0.15 tpy and 0.30
tpy respectively.
The operator used the following equation to Calculate the annual heat input: Heat Input (MM Btu/yr) _ [Uncontrolled VOC routed to combustor (ton/yr)]'[2000 lb/ton]/[MW (Ib/Ib-mol)]`[379.41 scf/Ib-molr[i/VOC moI %]•[Heat Content
(Btu/scf)j" [1MMBtu/1,000,000 Btu]. The operator expressed the values for molecular weight, VOC mol%and beat content used in the equation were obtained from the flash gas stream in the ProMax simulation provided In the application. The values
used in the equation are as folow: (i) Molecular weight:42.79661b/Ib-mol, (ii)VOC mol %: 57.721377%, (iii) Heat Content: 2392.31 Btu/scf. Using these values, the operator calculated a heat input of 5,995.43 MMBtu/yr. Since this value is more
conservative than the value calculated above using prescribed methods, it will be used for permitting pwposes.
2. The twoenclosed combustors used to control emissions from the hydrocarbon liquid loadout at this facility are not used to control emissions. from any other sources. As a. result, only NOx and CO emissions resulting from the hydrocarbon liquid':
loadout need to be evaluated for APEN applicability. In this case NOx and CO emissions from the hydrocarbon liquid loadout are below APEN reporting thresholds. Due to this; the permit will not contain emission limits or emission factors for NOx and
CO.
3. Pilot light emission calculations for the two combustors used to control emissions from the hydrocarbon liquid loadout are included in this analysis. -
4. Initial and periodic opacity obserVatlonsaie addressed by the 0&M plan. As a result, the permit does not contain initial or periodic opacity testing.
S. The NOS for this source was provided on 05/04/2020. As a result, an updated NOS is not required as part of the self -certification requirements in the permit.
6. According to the O&M plan, the emissions resulting from the loadout are directly routed to the two (2) enclosed combustors. This facility does not utilize a vapor balance system.
7. The operator was provided with a. draft permit and APEN redline to review prior to public comment. The operator reviewed both documents and expressed they had no comments
Section 09 -SCC Coding and Emissions Factors IFor Inventory Use Only)
AIRS Point q
004
Process i
01
SCC Code
..3201-32 Crude Oil: Submerged Loading Normai Service is 0.5)
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM30 ,., .; lb/1,000 gallons transferred
PM2.5 1.50E-03 0 lb/1,000 gallons transferred
SOx 1.27E-04 lb/1,000 gallons transferred
NOx 2.91E-02 lb/1,000 gallons transferred
VOC 5.6 05 lb/1,000 gallons transferred
CO 5.96E-02 0 lb/1,000 gallons transferred
Benzene 9.90E-03 95 Ib/1,000 gallons transferred
Toluene 0.00E300 95 lb/1,000 gallons transferred
Ethylbenzene 0.008.00 95 lb/1,000 gallons transferred
Xylene 0.002,00 95 lb/1,000 gallons transferred
n -Hexane 8.60E-02 95 lb/1,000 gallons transferred
224 TMP 200E+00 95 16/1,000 gallons transferred
3 of C:\Users\hslaught\Desktop\123A0F2\20WE0497.CP1
Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Regulation 3 Parts A and B -APEN and Permit Requirements
Source is in the Non, Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part B, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
IYou have indic'.ated that source is in the Nen-Attainment Aree
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site (e.g., well pad) (Regulation 3, Part 8, Section II.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions from the greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7
I8ourge requlreu,, ra permit
Colorado Regulation 7 Part D Section II.C.5.
1. Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, natural gas compressor station or natural gas processing plant?
2. Does the facility have a throughput of hydrocarbon liquids loadout to transport vehicles greater than or equal to 5,000 barrels?
Yes
Yes
No
No
0
Yes.:..
yes
!The hydrocarbon liquids loadout source is subject to Regulation */ Part 0 Section
Section II.C.5.a.(i) - Compliance Schedule
Section II.C.S.a.(ii) - Operation without Venting
Section II.C.5.a.(iii) - Loadout Equipment Operation and Maintenance
Section II.C.5.a.(iv) - Loadout observations and Operator Training
Section II.C.5.a.(v) - Records
Section II.C.5.a.(vl) - Requirements for Alr Pollution Control Equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations, and Air Quality Control Commission regulations. This document
is not a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. Thls document does not change or substitute for any
law, regulation, or any otherlegally 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 anon -mandatory language such as "recommend,""may,"
"should," and "can," is intended to describe APCD interpretations and recommendations. Mandatory terminology such as "must" and "required" are intended to describe controlling requirements under
the terms of the Clean Air Act and Air Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself.
Go to next question.
Go to the next question
Go to next question
Go to next question
Go to next question
The loadout requires a permit
Go to next question.
Source is subject to Regulation 7 Part D Section II.C.5.
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:
AIRS ID Number: 123 / A0F2 / 062
Section 1 - Administrative Information
Company Name1: PDC Energy, Inc.
Site Name: Sanford 21-29 Pad
Site Location: NENW Sec 29 T5N R66W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address?:
Jack Starr
(303) 860-5800
Jack.Starr@pdce.com
Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
? Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
26_ •
480824
1I
apkainocoLoRmao
Permit Number:
20WE0495
AIRS ID Number: 123 /A0F2 / 002
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 S312.50 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 name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exemptigrandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Initial permit request for condensate storage tanks at a new facility
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:
For new or reconstructed sources, the projected start-up date is:
Condensate Storage Tanks
TK-1
1 /23/2020
Normal Hours of Source Operation: 24 hours/day
7
Storage tank(s) located at: E] Exploration & 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?
O
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput z 500 bbl/day?
Yes
No
GI
■
If "yes", identify the stock tank gas -to -oil ratio:
0.002744
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
Are you requesting ?. 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ?.6 ton/yr (per storage tank)?
Yes
No
•
■
' ptdcoLORADO
ia�at
Redlines per application. (HDS 10/20/2020)
Permit Number:
20WE0495
AIRS ID Number: 123 / A0F2 / 002
Section 4 - Storage Tank(s) Information
ICondensate Throughput:
Actual Annual Amount
(bbl/year)
1,382,796
From what year is the actual annual amount?
Projected
Average API gravity of sates oil: 54.5 degrees
❑ Internal floating roof
Tank design: 0 Fixed roof
Requested Annual Permit Limits
(bbl/year)
1,659,360
RVP of sales oil: 9.7
❑ 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 .
6
2,400
1/2020
1/2020
Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites On
y)
API Number
Name of Well
Newly Reported Well
05
- 123
- 45509
Sanford 30C -30-M
MI
05
- 123
- 45510
Sanford 30N -30A -M
GI
05
- 123
• 45508
Sanford 30N -306-M
0
05
- 123
- 49929
Sanford 31 N -306-M
0
05
- 123
- 45545
Sanford 31 -N -30C -M
GI
s Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.376078 / -104.804376
0 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 Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack depth (inches):
3
GC
COLORADO
esith Ina �: vc
Permit Number:
20WE0495
AIRS ID Number: 123 / A0F2 / 002
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: VOC and HAPS
Size:
Make/Model: Blower - TBD
Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 35 %
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPS
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model: 4 x 96" IES
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 95
Minimum Temperature:
Waste Gas Heat Content: 2,392.31 Btu/scf
Constant Pilot Light: Yes ❑ No Pilot Burner Rating: 0,02 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 (EEtP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 19.9 psig
Describe the separation process between the well and the storage tanks: Three -Phase Separator
to Gas Buster
Redlines per application. (HDS 10/20/2020)
4I
COLORADO
Permit Number: 20WE0495
AIRS ID Number:
123 / A0F2 / 002
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? ❑ 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 Descri Description
p
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
VOC
VR.0 / Enclosed Combustor
100%
100% / 95%
NOx
CO
HAPs
VRU / Enclosed Combustor
100%
100% / 95%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Pollutant
Source
Uncontrolled
Controlled
Uncontrolled
Controlled
Uncontrolled
Basis
Units
(AP -42,
WS, etc.)
Emissions
(tons/year)
Emissions$
(tons/year)
Emissions
(tons/year)
Emissions
(tons/year)
VOC
1.0032 / 6.13
lb/6N; t6/M1Ascf
ProMax/AP-42
693.6
12.14
832.33
14.57
NO.
0.1380 / 0.068
Ib/MMBtu
TCEQ/AP-42
1.25
1.25
1.5
1.5
CO
0.2755 / 0.31
IWMMBtu
TCEQ/AP-42
2.55
2.55
3,05
3.05
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14.03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service CAS
(CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
ncontroed
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(Ibs/year)
Controlled
Emissions8
(ibs/year)
Benzene
71432
0.0029
lb/bbl
ProMax
4,007.2
70.1
Toluene
108883
0.0039
tb/bbl
ProMax
5,376.5
94.1
Ethylbenzene
100414
846E-05
lb/bbl
ProMax
117 (DM)
2.1 (DM)
Xylene
1330207
0.0014
lb/bbl
ProMax
1,885.7
33
n -Hexane
110543
0.0261
Ibtbbl
ProMax
36,055.2
631
2,2,4-Trimethylpentane
540841
6.80E-05
Ib/bbl
ProMax
94 (DM)
1.6 (DM)
❑ No
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Redlines per application. (HDS 10/20/2020)
2/21O19 S I
COLORADO
Apartment *Mt.
VW* tnr4eoerm
Permit Number:
20WE0495
AIRS ID Number: 123 / AOF2 / 002
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.
Sig
re of Legally Authorized Person (not a vendor or consultant)
Jack Starr
Senior Air Quality Representative
Name (print)
Title
Check the appropriate box to request a copy of the:
[]✓ Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303)692-3175
OR
(303) 692-3148
APCD Main Phone Number
(303) 692-3150
!COLORADO
6 1 l �. «�
..�.� e. .
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
PDC Energy, Inc.
Source Name:
Sanford 21-29 Pad
Emissions Source AIRS ID2:
N/tt-/ / 123/AOF2/002
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05-123-49930
Sanford 32N -30B -M
L/
05 - 123 - 49917
Sanford 32N -30C -M
.1
05 - 123 - 45533
Sanford 4C -30-M
►1
05 - 123 - 45534
Sanford 4N -30A -M
►/
05 - 123 - 45532
Sanford 4N -30B -M
.1
05 - 123 - 45511
Sanford 4N -30C -M
El
05 - 123 - 49925
Sanford 5C -30-M
El
05 - 123 — 49923
Sanford 5N -30B -M
►1
05 - 123 - 49931
Sanford 5N -3C -M
L
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
■
- -
❑
- -
■
- -
❑
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 Addendum
Produced Water Storage Tank(s) APEN
Form APCD-207
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 produced water 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, condensate 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:
245we411-9.6
AIRS ID Number: 123 / A0F2 / Cle3
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Sanford 21-29 Pad
Site Location: NENW Sec 29 T5N R66W
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 Address?: 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.
? Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
430327
i Sf
Departramt
COLORADO
Permit Number: 20WE0496
AIRS ID Number: 123 / A0F2 / 003
Section 2 - Requested Action
El NEW permit OR newly -reported emission source
Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP05 ❑ 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 -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ 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 It Notes: Initial permit request for produced water storage tanks at a new facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
' 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:
Produced Water Storage Tanks
TK-2
1/23/2020
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week
❑✓ Exploration 8 Production (EEtP) site
52
weeks/year
❑ Midstream or Downstream (non EEO)) site
Will this equipment be operated in any NAAQS nonattainment area?
0
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
0
Yes
■
No
Are these storage tanks located at a commercial facility that accepts oil production
wastewater for processing?
Yes
D
No
■
Do these storage tanks contain less than 1% by volume crude oil on an annual average basis?
0
Yes
■
No
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per -storage tank)?
Yes
No
0
■
tOIORADO
2 I c o Lo RaA Dbt
L - I16W8,b&nM mmt
❑ Upward
❑ Horizontal
Permit Number:
20WE0496 AIRS ID Number: 123 /A0F2 / 003
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Produced Water Throughput:.
Actual Annual Amount
(bbl/year)
774,168
Requested Annual Permit Limits
(bbl/year)
929,000
From what year is the actual annual amount?
Tank design:
Fixed roof
Projected
❑ Internal floating roof
❑ 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-2
2
800
1/2020
1/2020
Wells Serviced by this Storage Tank or Tank Batteryb (MP Sites On y)
API Number
Name of Well
Newly Reported Well
05
123
- 45509
Sanford 30C -30-M
GI
05
- 123
- 45510
Sanford 30N -30A -M
GI
05
- 123
- 45508
Sanford 30N -306-M
p
05
- 123
• 49929
Sanford 31 N -306-M
GI
05
- 123
- 45545
Sanford 31 -N -30C -M
SI
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 EEtP 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)
40.376078/-104.804376
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):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑ Circular interior stack diameter (inches):
❑ Square/ rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-207 Produced Water Storage Tank(s) APEN - Revision 12/2019
GOcowaAoa
3 I Hoeft°
Permit Number:
20WE0496
AIRS ID Number: 123 / A0F2 / 003
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:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
%
❑
Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model: 4 x 96" IES
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature:
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating:
95 %
Waste Gas Heat Content: 822.64 Btu/scf
MMBtu / hr
0.02
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (MP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 388 psig
Describe the separation process between the well and the storage tanks: Three -Phase Separator
Redlines per application. (HDS 12/17/2020)
4 ISO
COLORADO
s ri � Nsai
Permit Number:
20WE0496
AIRS ID Number: 123 / A0F2 / 003
[Leave blank unless APCD has already assigned a permit M 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? 0 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 Descri Description
p
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 emrssrans data? Projected
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
fAP-42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
0.04284
Ib/bbl
FLA & AP -42
16.58
0.83
19.9
0.99
NO.
0.1380
Ib/MMBtu
TCEQ
0.51
0.51
0,61
0.61
Co
0.2755
Ib/MMBtu
TCEQ
1.02
1.02
1.22
1.22
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 produced water 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?
El Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
(CAS)
Service CAS
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP 42,
Mfg., etc.)
Uncontrolled
Emissions
(Ibs/year)
Controlled
Emissions8
(Ibs/year)
Benzene
71432
0.0017
lb/bbl
FLA & AP -42
1,336.4
66.8
Toluene
108883
0.0020
lb/bbl
FLA & AP -42
1,555.1
77.8
Ethylbenzene
100414
6.06E-05
lb/bbl
FLA & AP -42
46.9 (DM)
2.4 (DM)
Xylene
1330207
5.43E-04
lb/bbl
FLA & AP -42
420.1
21.0
n -Hexane
110543
2.11E-03
lb/bbl
FLA & AP -42
1,633.9
81.7
2,2,4-Trimethylpentane
540841
7 Attach produced water 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.
Form APCD•207 Produced Water Storage Tank(s) APEN - Revision 12/2019
°airwomen et POW
5 I iCOLORADO
Redlines per updated calculations. (HDS 12/17/2020)
Permit Number:
20WE04%
•
t.
AIRS ID Number: 123 /A0F2 / 003
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 GP05 or GP08, I further certify that.
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Signatu of legally Authorized Person (not a vendor or consultant) Dat
Jack Starr Senior Air Quality Representative
Name (print)
Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
❑✓ Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303)692-3175
OR
(303)692-3148
APCD Main Phone Number
(303)692-3150
COLORADO
O...mond Dab.
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
PDC Energy, Inc.
Source Name:
Sanford 21-29 Pad
Emissions Source AIRS ID2:
N/A/ / 123/A0F2/003
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 49930
Sanford 32N -30B -M
►1
05 - 123 - 49917
Sanford 32N -30C -M
►1
05 - 123 - 45533
Sanford 4C -30-M
/1
05 - 123 - 45534
Sanford 4N -30A -M
►1
05 - 123 - 4_5532
Sanford 4N -30B -M
05 -123 - 45511
Sanford 4N -30C -M
.1
05 - 123 - 49925
Sanford 5C -30-M
./
05 - 123 — 49923
Sanford 5N -30B -M
-.-
05 - 123 - 49931
Sanford 5N -3C -M
L
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
■
- -
❑
- -
❑
- -
❑
.- -
❑
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 ID by the APCD, enter
N/A
Form APCD-212
TK-2 Addendum
Hydrocarbon Liquid Loading APEN
Form APCD-208
caP�lE 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 hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, 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 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:
-24,1,40)11417
AIRS ID Number: 123 / A0F2 / 00 -
bi_arox untess _. _
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Sanford 21-29 Pad
Site Location: NENW Sec 29 T5N R66W
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 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.
,SiOn 1,, _. 7 7
430825
jee 1 COLORADO
xeisn..roe.�wn
Permit Number:
20WE0497 AIRS ID Number: 123 / A0F2 / 004
[leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑Q NEW permit OR newly -reported emission source
El Request coverage under construction permit
❑ Request coverage under General Permit GP07
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 fuel or equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership' ❑ Other (describe below)
OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PER/AIT ACTIONS -
[3 Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info li Notes: Initial permit request for condensate liquid loadout at a new facility
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.
Section3 - General Information
General description of equipment and purpose: Loading of condensate from storage tanks to tank trucks
Company equipment Identification No. (optional): LOAD -1
For existing sources, operation began on:
1/23/2020
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
p
■
Is this equipment located at a stationary source that is considered a Major Source of (HAP)•
emissions?
Yes
No
Igl
Does this source load gasoline into transport vehicles?
Yes
No
■
GI
Is this source located at an oil and gas exploration and production site?
Yes
No
GI
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annualIS
average?
Yes
No
■
Does this source splash fill less than 6,750 bbl of condensate per year?
Yes
No
' 15I
■
Does this source submerge fill less than 16,308 bbl of condensate per year?
Yes
No
■
O
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 12/2019
2i16e
COLORADO
6.p..u.wt m Mue
*LW 6InM:awe*
Permit Number: 20WE0497 AIRS ID Number:
123 /A0F2/ 004
Section 4 - Process Equipment Information
Product Loaded: 0 Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loadeds:
829,860
bbl/year
819,680
This product is loaded from tanks at this facility into: Tank Trucks
(e.g. "rail tank cars" or "tank trucks")
Actual Volume Loaded:
691,398
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
Average temperature of
bulk liquid loading:
F
True Vapor Pressure:
Psia ® 60 `F
Molecular weight of
displaced vapors:
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loadeds:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
lb/ft3
Load Line Volume:
ft3/truckload
Vapor Recovery Line Volume:
ft3/truckload
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.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.376078 / -104.804376
0 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 Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches):
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack depth (inches):
0
3 ISO
coeoRM:8o
Beath �
Redlines per application. (HDS 10/20/2020)
Permit Number: 20WE0497
AIRS ID Number:
123 / AOF2 / 004
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.
❑ Loading occurs using a vapor balance system:
Requested Control Efficiency:
%
❑ Combustion
Device:
Used for control of: VOC and HAPS
Rating:
Type: Enclosed Combustor
MMBtu/hr
Make/Model: TBD
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: °F Waste Gas Heat Content: 2,392.31 Btu/scf
Constant Pilot Light: ❑� Yes ❑ No Pilot Burner Rating: 0.02 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 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)
PM
SOx
NO.
CO
VOC
Enclosed Combustor
100%
95%
HAPs
Enclosed Combustor
100%
95%
Other:
❑r Using State Emission Factors (Required for GP07) VOC Benzene n"Hexane
r❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑ Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled
Source
(AP -42,
Uncontrolled
Controlled
Uncontrolled
Controlled
Basis
Units
Mfg., etc.)
Emissions
(tons/year)
Emissionsb
(tons/year)
Emissions
(tons/year)
Emissions
(tons/year)
PM
SOx
NOx
0.1380 / 0.068
Ib/MMBtu
TCEQ / AP -42
N/A
0.42 (DM)
N/A
0.51 (DM)
CO
0.2755 / 0.31
Ib/MMBtu
TCEQ / AP -42
N/A
0.87
N/A
1.04
VOC
0.2360 / 6.13
tblbbl; tb/MMsc(
CDPHE / AP.42
81.59
4.08
97.90
4 90
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 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
coLoax Do
4 Heath&
Redlines per application. (HDS 10/20/2020)
Permit Number: 20WE0497
AIRS ID Number:
123 / AOF2 / 004
Section 8 - 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?
❑✓ Yes ❑ No
If yes, use the following 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
Obs/year)
Controlled
Emissions
Obs/yeor)
Benzene
71432
0.0004
Ib/bbI
State Approved
287.62
14.38
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
0.0036
lb/bbl
State Approved
2,495.95
124.80
2,2,4-Trimethylpentane
540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
sk-1C
Signatur of Legally Authorized Person (not a vendor or consultant) (late
Jack Starr Senior Air Quality Representative
Name (print)
Title
Check the appropriate box to request a copy of the:
[] Draft permit prior to issuance
Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $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-B 1
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
COLOR600
5I
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