HomeMy WebLinkAbout20203650.tiff .. COLORADO
Department of Public
are"E Health&Environment
RECEIVED
NOV 3 0 2020
Weld County - Clerk to the Board WELD COUNTY
1150 O St COMMISSIONERS
PO Box 758
Greeley, CO 80632
November 23, 2020
Dear Sir or Madam:
On November 24, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
PDC Energy, Inc - J Klein 7 Sec HZ. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe 'tc
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director j,' +*;
Pub I ; C Re v e v.) cc..pLOP1HL(c6),Pc401-t/cRicw/c0, 2020-3650
12 o�„(sM)
/l6/20
12./lo/2O
MYu Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: PDC Energy, Inc - J Klein 7 Sec HZ - Weld County
Notice Period Begins: November 24, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: PDC Energy, Inc
Facility: J Klein 7 Sec HZ
Well Production Facility
SWSE quadrant of Section 7, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc wishes to reduce requested permitted
emissions by reducing requested condensate throughput.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• The source is requesting a federally enforceable limit on the potential to emit in order to avoid
other requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 17WE1191 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
'Z ' Depattment at Public
1 I �iii� Heaith 6 Eav#ronrnent
rY COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 17WE 1191 Issuance: 2
Date issued: XX/XX/XXXX
Issued to: PDC Energy, Inc.
Facility Name: J Klein 7 Sec HZ
Plant AIRS ID: 123/9F73
Physical Location: SWSE SEC 7 T5N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
Sixteen (16) 538 barrel fixed roof liquid
TK-1 001 manifold storage vessels used to store Enclosed Combustors
condensate
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
Page 1 of 9
C COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO,t VOC CO Type
TK-1 001 --- 1.8 16.9 3.8 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on
the previous twelve months' data. The permit holder must calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
6. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Control Device Pollutants
Equipment ID Point Controlled
TK-1 001 Enclosed Combustor VOC and HAP
PROCESS LIMITATIONS AND RECORDS
7. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Page 2 of 9
a r7 COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility AIRS Process Process Parameter Annual Limit
Equipment ID Point
01 Condensate Throughput 352,830 barrels
TK-1 001 02 Combustion of pilot 1.2 MMscf
light gas
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 ste or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks;and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
Page 3 of 9
, ,,:M COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING a MAINTENANCE REQUIREMENTS
15. Upon startup of these points, 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 O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. All previous versions of this permit are cancelled upon issuance of this permit.
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
Page 4 of 9
isr,7:: COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D)
GENERAL TERMS AND CONDITIONS
21. This permit and any attachme■ts must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
Page 5 of 9
0 C r :: COLORADO
_/ Air Pollution Control Division
tie Department of Public Health b Environment
Dedicated to protecting and improving tl-e health and environment of the people of Colorado
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 November 16, 2018 Issued to PDC Energy, Inc.
Issuance 2 This Issuance Issued to PDC Energy, Inc. Operator reduced
permitted emissions by reducing requested
condensate throughput.
Page 6 of 9
rYy COLORADO
Air Pollution Control Division
`�� Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, 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.colarado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's
analysis of the specific compounds emitted if the source(s) operate at the permitted limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 1724 86
Toluene 108883 2404 120
Ethylbenzene 100414 89 4
001 Xylenes 1330207 1041 52
n-Hexane 110543 14249 712
2,2,4 540841 63 3
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 1.015x10-2 1.015x10-2 TNRCC and Promax
CO 2.027x10-2 2.027x10-2 TNRCC and Promax
VOC 1.9141 9.5705x10-2 Promax
71432 Benzene 4.887x1O3 2.444x10"4 Promax
Page 7 of 9
COLORADO
��/ Air Pollution Control Division
Department of Public Health fir Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
108883 Toluene 6.812x10-3 3.406x10-4 Promax
1330207 Xylene 2.950x10-3 1.475x10-4 Promax
110543 n-Hexane 4.038x10-2 2.018x10-3 Promax
Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific VOC
and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax
simulation. The site specific sample used in the ProMax simulation was obtained from the J Klein 7Y-201 well
on 10/19/2017. The NOx and CO TNRCC emission factors(0.1380 lb/MMBtu and 0.2755 lb/MMBtu respectively)
were converted to units of lb/bbl using a heat content of 2342.2 Btu/scf, molecular weight of 41.9 lb/lbmole,
a standard molar volume of 379.41 scf/lb-mole, and a VOC mol% of 55.19%. Actual emissions are calculated
by multiplying the emission factors in the table above by the total condensate throughput.
Process 02: Combustion of pilot light
Uncontrolled Emission
CAS# Pollutant Factors Source
lb/MMSCF
NOx 77.2 AP-42 Chapter 13.5
VOC 6.1 AP-42 Chapter 1.4
Table 1.4-2
CO 352.2 AP-42 Chapter 13.5
Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5
NOx and CO emission factors (0.068 lb/MMBtu and 0.31#b/MMBtu respectively) by a heat value of 1,136
Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4
emission factor by a heat value of 1,136 Btu/scf. Actual emissions are calculated by multiplying the emission
factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a
constant rate of 15.6 scf/hr. There are a total of nine (9)combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 140.4 scf/hr.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN must be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC. True Minor Source of CO, NOx,
Et HAP
Page 8 of 9
r COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PSD True Minor Source of: CO Et NOx
NANSR Synthetic Minor Source of: VOC.
MACT HH Area/Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN -Subpart XXXXXX
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Diego Chimendes
Package#: 433506
Received Date: 7/16/2020
Review Start Date: 10/1/2020
Section 01-Facility Information
Company Name: PDC Energy,Inc. Quadrant Section Township Range
County AIRS ID: 123 SWSE 7 5N 64
Plant AIRS ID: 9F73
Facility Name: J Klein 7 Sec HZ
Physical
Address/Location: SWSE quadrant of Section 7,Township 5N,Range 64W
County: Weld County
Type of Facility: Exploration&Production.Well Pad
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Point# Permit#
Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit
001 Storage Tank TK-1 Yes 17WE1191 2 Yes Modification
Section 03-Description of Project
PDC Energy,Inc.(PDC)submitted an application requesting modification of permit 17WE1191,PDC wishes to reduce requested permitted emissions by reducing
requested condensate throughput.
This point source is APEN-required because uncontrolled V0C emissions are greater than 1 tpy and uncontrolled emissions of at least one non-criteria pollutant is
greater than 250 tpy.(Regulation 3 Part A Section 11.6.3.)Point source is permit-required because uncontrolled facility-wide VOC emissions are greater than 2 tpy.
(Regulation 3 Part B Section II.D.2.).
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in order to
avoid other requirements.(Regulation 3 Part B Sections III.C.1.d.).
Point source is not subject to ambient air impact analysis.(Regulation 3 Part D Section 11.4.44).
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 Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: 1O2 Nox CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) _
Title V Operating Permits(OP) _ ✓ ❑
Non-Attainment New Source Review(NANSR) ✓
Is this stationary source a major source? No
Colorado Air Permitting Project
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) _
Title V Operating Permits(OP) ❑
Non-Attainment New Source Review(NANSR)
•
Storage Tank(s)Emissions Inventory
Section 01-Administrative Information
'Facility AIRs ID: 123 9F73 001
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid Cp)1etina2
Detailed Emissions Unit Sixteen(16)538 barrel fixed roof,liquid manifold condensate storagerve sS a rOlfge014-NPIVAgiSMIVOLILMIC
lc Description: "'> 4. '
Emission Control Device Eight(8)Cimarron 48'.&one(1)Cimarron 60"enclosed combustors. a 4 '. 5'
Description: .. ,
Requested Overall VOC&HAP Control Efficiency%: 95.0
Limited Process Parameter Enid Throughput'; „
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)Actual Throughput= 294,025.0 Barrels(bbl)per year
Requested Permit Limit Throughput= ,352,830.0 Barrels(bbl)per year Requested Monthly Throughput= 25566.4 Barrels(bbl)per month
Potential to Emit(PTE)Condensate Throughput= 352,830.0 Barrels(bbl(per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2342.2.Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= scf/bbl
Molecular Weight= 41.9 Ib/Ibmol
VOC mol%= 55.19% -
Molar Volume= 379.4 scf/Ibmol
Actual heat content of waste gas routed to combustion device- 21,633.2 MMBTU per.year
Requested heat content of waste gas routed to combustion device= 25,959.7 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 25,959.7 MMBTU per year
Control Device
Pilot Fuel Use Rate: 140.4 scfh 1.2 MMscf/yr
Pilot Fuel Gas Heating Value: 1136 Btu/scf 1397.2 MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions? Nj.
Emission Factors Condensate Tank
Uncontrolled Controlled
1
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 1.9141E+00 9.5705E-02 %Benzene .4.887E 03 2.444E-04 } -
Toluene 6.812E-03 3.406E-04 5 1 ,.1
Ethylbenzene .2.517E-04 1.259E-05 4 s+ ad'1u,'"
Xylene 2.950E-03 1.475E-04 1aI"`) ,:,
n-Hexane 4.038E-02 2.019E-03 E ":9 ',r't3 r -s
224TMP 1.777E-04 8.886E-06 ?-?'Kt 1 2C .fir
Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 5.482E-04 AP-42Tables,-`2(PM10/PM2.5)
PM2.5 0.0075 5.482E-04 AP-42Table14-2(PM10/SM.2.5)
SOx 0.0006 4.328E-05 _Other Explain
NOx 0.1380 1.015E-02 TNRCC Flare Emissions Guidance(NOx) .,-;
CO 0.2755 2.027E-02 TNRCCflaW`Wstissibns,Guidance(CO)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 8.5 AP-42 Table' 1P/PM.2.5) ; :' -
PM2.5 0.0075 8.5 AP-42 TabiO- 19)4991.2.5)
SOx 0.0006 0.7 AP-42 Ta41e )
NOx 0.0680 77.2 AP-42 Char tjustcial Flares(NOxk'
VOC 0.0054 6.1 AP-42 Table .).."
CO 0.3100 352.2 AP-42 Chia _ .5 Indust€ial Flares(COL,_ VS
Section ES-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons)year) (tons/year) (lbs/month)
PM10 0.1 0.1 0.1 0.1 0.1 17.3
PM2.5 0.1 0.1 0.1 0.1 0.1 17.3
SOx 0.0 0.0 0.0 090 0.0 1.4
NOx 1.8 1.5 1.5 LS 1.8 312.3
VOC 337.7 281.4 14.1 337.7 16.9 2868.6
CO 3.8 3.2 3.2 313 3.8 644.2
3 of 9 X:\PA\2017\17WE1191.CP2 -
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) Ilbs/year) (Ibs/year) (Ibs/year) Ohs/year)
Benzene 1724.4 1437.0 71.9 1724 86
Toluene 2403.5 2002.9 100.1 2404 120
Ethylbenzene 88.8 74.0 3.7 89 4
Xylene 1041.0 867.5 43.4 1041 52
n-Hexane 14248.9 11874.1 593.7 14249 712
224 TMP 62.7 52.3 2.6 63 3
•
4 of 9 K:\PA\2017\17WE1191.CP2
Storage Tanks)Emissions Inventory
Section 06-Regulatory Summary Analysis - \
Regulation 3,Parts A,a Source requires a permit
Regulation 7,Part D,Section LC,D,E,F Storage tank is subject to Regulation 7,Part D,Section I.C-F
Regulation 7,Part D,Section I.G,C Storage Tank is not subject to Regulation 7,Section I.G •
Regulation 7,Part D,Section 11.6,C.1,C.3 Storage tank is subject to Regulation 7,Part D,Section II,B,C.1&C.3
Regulation 7,Part D,Section II.C.2 Storage tank is subject to Regulation 7,Part D,Section II.C.2
Regulation 7,Part D,Section II.C.4.a.(i) Storage Tank is not subject to Regulation 7,Part D,Section II.C.4.a(i)
Regulation 7,Part.D,Section ll.C:4.a.(ii) Storage Tank is not subject to Regulation 7,Part D,Section ll.C.4.a(ii),b-f
Regulation 6,Part A,NIPS Subpart Kb Storage Tank is not subject to NSPS Kb ---
Regulation 6,Part A,NIPS Subpart 0000 Storage tank is not subject to NSPS 0000.
NIPS Subpart 0000a Storage Tank is not subject to NIPS 0000a
Regulation 8,Part E,MACTSubpart HH - Storage Tank is not subject to MACE HH
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks,does the company use the state default emissions factors to
estimate emissions?
',yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than ar equal to 80 tpy?
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions? t.
If yes and if there are flash emissions,are the emissions factors based an a pressurized liquid sample drawn at the facility being
permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash liberation analysis)?This sample ''f' c
should be considered representative which generally means site-specific and collected within one year ofthe application received
date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it may be appropriate to use an
older site-specific sample.
If no,the permit will contain art"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
OX,41a.'
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
1.Site-specific Emission Factors:The site specific sample used to establish emissions factorsforthis source was obtained within a year of the first Issuance application.The sample was obtainedfrom the.)Klein 7V-
201 well.This well is one of the eight wells drilled at this facility and there were no significant changes to the facility sine the development of the emissionsfactors,As a result,the permit will not require initial testing
in order to obtain a new site specific sample.It should be noted that the sample includes sample probe temperature and pressure in conjunction with gauge pressure and temperature.
2.Secondary Emissions Calculations:
2.1 Operator used the following equation to calculate the annual heat input.
Heat Input(MAIMu/y-)=[Uncontrolled VOC(ton/yr)].[2000(lb/ton)]+MW(lb/lbrnol)*[379.41(ocf/lbmol)]s[1/V0C mot%n]*[Heat Content(Btu/sef)]a[1MMBtu/(1000,000 Btu)).
The values used in the equation were obtained from a ProMaxsimulation used to calculate emissions and develop emission facto-_The values used are as follow:(i)Molecular weight:41.9 lb/Ib-mol,(ii)VOC mol
55.2%,(iii)Heat Content-2342.2 Iltu/scf. - - -
3.Pilot Light Emissions Calculations:Operator assumed pilot fuel to have the same conditions of field gas which is consistent with the plant design provide by operator.The permit will not contain initial or periodic
opacity testing for the enclosed combustor(s)because the O&M plan approved for this source requires weekly visible emissions observations of the enclosed combustor(s).A throughput limit is included in the permit
for pilot combustion.Emission factors and calculation methods for pilot light combustion emissions are also included in thenotesto permit holder.This information is included in the permit because pilot light
emissions contribute to the overall emissions from this source.Additionally It is important to include this information because throughput tracking and emission calculation methods are different than those used to
estimate emissions based on the condensate throughput.This clarity is important for accurately quantifying actual emissionsat this facility.
4.Permit draft was sent to operator for review.Operator had no comments.
Section 09-SCC Coding.and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process SCC C d Pollutant Factor Control% Units
001 01 ?�,, F 'l1;];aq(•Tn.,;; sad orking+breathing+fl ashing losses 7 PM10 0.01 0 lb/1,000 gallons Condensate throughput
PM2.5 0.01 0 lb/1,000 gallons Condensate throughput
SOx #REF! 0 lb/1,000 gallons Condensate throughput
NOx 0.25 0 lb/1,000 gallons Condensate throughput VOC 45.57 95 lb/1,000 gallons Condensate throughput
CO 0.51 0 lb/1,000 gallons Condensate throughput
Benzene 0.12 95 lb/1,000 gallons Condensate throughput
• Toluene 0.16 95 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons Condensate throughput
Xylene 0.07-. 95 lb/1,000 gallons Condensate throughput
n-Hexane 0.96 95 lb/1,000gallons Condensate throughput
224 TMP 0.00 95 lb/1,000 gallons Condensate throughput
•
5 of 9 . K:\PA\2017\17WE1191.CP2
•
•
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APES and Permit Requirements
source b in the Sun,y vaimsenehras •
ATTAINMENT
1. Areuncantrolled actual emissions from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Pert A,Section ll.D.1.a)? Source Requires an APEN.Go to
2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? Go to next question
3. Aretotal facility uncontrolled VOC emissions greater than 5 TPY,NOx greater than to TPY or CO emissions greater than town(Regulation 3,Part 8,Section ll.D.3)? Source Requires a permit
I':tti r indicated tie:se02, i0:attar-Assai„mint
NON-ATTAINMENT
1 Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY(Regulation 3,Part A,Section 11.0.1.a17 ==Source Requires an APES.Go to
2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 md1.14 and Section 2 for additional guidance on grandfather applicability)? N Go to neat question
3. Are total facility uncontrolled VOL emissions greater than 2TPY,NO4 greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)7 Vk'3'1. Source Requires a permit
ISo rnpulre, parnsft
Colorado Regulation 7,Pert D,Section 1.0-F&eu
1. Is this storage tank located In the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part D,Section 1,A.1)? Yee Continue-You have indicated th
2. Isuhis storage tank located at ail and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 7,Part 0,Section lA.1)7 Yes Continue-You have indicated th
3. ',Miss-tome.tankloceted ate natural gas processing plant(Regulation 7,Part D,Section 1,6)7 Storage Tank is not subject to Re
4. Does the storage tank contain condensate? -.
5. Doesthh storage tank exhibit"Flash"(e.g.storing non-stabilized liquids]emftsions(Regulation 7,part 0,Section l.G.2)?
6. Are unontrolled actual emissions ofthn storage tank equal to or greater than 2tons per year VOC(Regulation 7,Part 0,Section iD3a(ii))? Y ...:
Part D,Section 1.0.1-General Requirements for Air Pollution Control Equipment-Prevention of Leakage
Pang,Section 1.0.2-Emission Estimation Procedures
Part D,Sectlan IA-Emissions Control Requirements
Part 0,Section LE-Monitoring
Part CI,Section I,F-Recordkeeping and Reporting
Part 0,section I.G.2•Emissions Control Requirements
Part 0,Section I.C.1.a and b-General Requirements for Air Pollution Control Equipment-Prevention of Leakage
Colorado Regulation 7,Part D,Section II
1. Is this storage tank located at a transmission/storage facility? ._ Continue-You have indicated th
2. Is this storage tank[located at an oil and gas exploration and production operation,well production facility',natural gas compressorstations or natural gas processing plant"(Regulation 7,Part 0,Section 11.07 Yif5 Go to the next question-You he
3. Does this storage tank have a fixed roof(Regulation 7,Part 0,Section ll.A.20)7 '6*)SrM Go to the next question
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOL(Regulation 7,Part 0,Section ll.C,u.c)7 tErnXi TMa"'S�o`Source is subject to parts 00 Regi
Ica a§iscuhi2G+.,Bum �f— n7,curt P.5eclinn,l,sl,1.1&C3
Pact O,Section 11.8`—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part O,Section 0.0.1-Emissions Control and Monitoring Provisions
Part 0,Section 11.0.3 PecordkeepingRgi men[
5 Does the storagetank contain only"stabili.d"liquids(Regulation 7,Part 0,Section ILC2.W7 (Source is subject to all provison•
•
Part 0,Section II.C.2-Capture and Monitoring for Storage Tanks titled with Air Pollution Control Equipment
Isthe controlled storage tank located at a well production facility,natural gas compressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facility that was modified an or after May 1,2020,such
6. that an additional controlled storage v sel is constructed to receive an anticipated increase in throughput of hydrocarhon Squids orproduced water(Regulation?,Part 0,Section ll.C4.a.(I)? ._ Storage Tank is not subject to Re
Isthe controlled storage tankl d at a wellp od facility, l g rm p 0rstation,or natural gas processing plant constructed on or after January 1,2021 or located at afacilkythat was modified on or afterianuary 1, ;I
7. 2021,such that an additional controlled storage vessel is c nstructed to receive an anticipatedncrease In throughput ofhydrorarbon liquids or produced water(Regulation7,Part D Section R.C.4.a(ii)?
40 CFR Part 60 Subpart Ith Standards f P rf for Volatile Organic Liquid S Vessels
1. Is the individual storage vessel capacityg than qual to 75 cubic meters(m)T'472 BBLsl(40 CFR 60.110b(a))7 'tip to the next question
Z Does the storage vessel meet the following exemptonn 6o.111b(d)(4)7 52o rageTanks notsubject NSP5
a.Does the vessel has a design capacity less than or equal to 1,589.874 me["1!1,000 BBL]used for petroleum'or urdensate stored,processed,or treated priorto custody transfer'as defined in 60.111k?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 90 CFR,60.2)after July 23,1984(90 CFR 60.1106(a))? N!1
4. Does the tank meet the definition of"storage vessel"'in 60.111b? NA
5. Does the storage vessel store a"volatile organic liquid(VOCT5es defined in 60.111b? -
6. Does the storage vessel meet any one ofthef0llowing additional exemptions: Nn:
a.Is the storage vessel a pressure vessel designed to operate in excess of 209.9 MPa(-29.7 psi)and without emissions to the atmosphere 160.110b(d)121)7;or
b.The design capacity is greater than or equal to 151 m°('950 BBL]and stores a liquid with a maximum true vapor pressures less than 3.5 kPa(60.11ob(b))7;or I
c.The design capacity is greater than or equal to 75 M'("472 BBL(butlers than 151 ma("950 BBL)and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a.The d Ign capacity I greater M1equal to 151m[_950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kPaf or
b.The d ig p ity I greater than qualto75Me("472 BB/but less than 151 m'(-950 BBL)and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but lessthan 27.6 Me?
l,tt e stibi0tt,
40 CFR.Part 60,Subpart O0OO/0O0Oa,Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution
1. Isthb storage vessel located ate facility in the onshore all and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-You have Indicated th
2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)between August 23,2011 and September 18,20157 F1b',"°.'cihtu;'Storage Tanks not subject MPS
3, Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,2015? �'z/t Go to the next question
4. Are potential VOC emissions'from the individual storage vessel greater than or equal to 6 tons per year? *tom Storage Tank is not subject NSP5
5. Doezthis storage vessel meet the definition of"storage vessel"'per 60.5430/60.5430x? g�')V.,'- .E
6 Isihe storage vessel subject toad controlled-n accordance with requirements for storage vessels in 40CFR Part 60 Subpart Rh nr 40 CFR Part 63 Subpart HH? NA ..
[Note:If a storage vessel is previously determined to be subject to NSPS 0000/O00Oe due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to SSPS 0O00/000Oa per
60.5365(e)(2)/60.5305e(e)(2)even if potential VOL emissions drop below s tons per year]
40 CFR,Part 63,Subpart MALT HH,Oil and Gas Production Facilities
1. Is the storagetank located at an oil and natural gas production facility that meets either of the following criteria: Ir:-, [Continue-You have indicated th
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760(a)(2)];OR
b.Afacilty that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmsrion and storage source category or is delivered to a final end user'(63.760(ai(3))7
2. Isthetank located at a facility that b major'for HAPs? if; Storage Tank is not subject MAC
3. Does thetank meet the definition of"storage vessel"'in 63.761?
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"'per 63.7617 '.i�n".y
5. Is thetank su Wert to control requirements under 40 CFR Part 60,Subpart Kb or subpart 0000? ' au
I5t mge'Tank is not su6jc t to MAC:
Subpart A,General provisions per§63.764(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
463.774-Recordkeeping
§63.775-Reporting
RACT Review
PACT review Is required if Regulation 7 does not apply AND If the tank is in the non-attainment area.If the tank meets both criteria,then review RACT requirements:
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 padicularsituation based upon the individual facts and circumstances.This document does not change or substitute for any law,regulation.
or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document aid the language of the Clean Air Act„its implementing regulations,
and Air Quality Control Commission regulations,the language of the statute or regulation will control.The use of non-mandatory language such as'recommend,"'may,"'should,"and"can,"is intended to
describe APCD interpretations and recommendations.Mandatory terminology such as'must"and'squired"are intended to describe controlling requirements under the terms of the Clean Air Act and Air
Qualify Control Commission regulations,but this document does not establish legally binding requirements in and of itself
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name PDC Energy,Inc.
County AIRS ID 123 History File Edit Date 11/17/2020
Plant AIRS ID 9F73 Ozone Status Non-Attainment
Facility Name J Klein 7 Sec HZ
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 0.5 0.5 0.0 0.0 77.8 1,218.7 0.2 67.2 34.2 0.5 0.5 0.0 0.0 12.2 68.0 0.2 21.6 2.3
Previous Permitted Facility total 0.4 0.4 0.0 0.0 75.9 1,218.5 0.0 65.6 34.1 0.4 0.4 0.0 0.0 10.3 67.7 0.0 20.0 2.2
001 17WE1191 Sixteen(16)538 bbl fixed roof 1.8 337.7 3.8 9.8 1.8 16.9 3.8 0.5 Point updated on'10/01/2020.Reducing requested
condensate storage vessels emissions.DC 10/01/2020.
002 GP07 Hydrocarbon Loadout 0.7 133.4 1.4 2.3 0.7 10.0 1.4 0.1 No Change
003 GP02 SI RICE GM Vortec 5.7L,4SRB,88 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No Change
HP(site rated),SN:13218537 .
SI RICE GM Vortec 5.7L,4SRB,88
004 GP02 HP(site rated),SN: 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No Change
1 OCH MM411120033
SI RICE GM Vortex 5.7L,4SRB,88
005 GP02.CN HP(site rated),SN. - 0.0 0.0 Cancellation received on 07/16/2020
10CHMM503060025
SI RICE GM Vortec5.7L,4SRB,88
006 GP02.CN HP(site rated),SN: 0.0 0.0 Cancellation received 11/15/18.Source no longer
10CHMM411120035 . exists at the facility.
007 GP02.CN SI RICE GM Vortec 5.7L,4SRB,88 0.0 0.0 Cancellation received 04/23/18.Source no longer
HP(site rated),SN:13218522 exists at the facility.
SI RICE GM Vortex 5.7L,4SRB,88
008 GP02.CN HP(site rated),SN: 0.0 0.0 Cancellation received 07/27/18.Source no longer
1OCHMM310030034 .. exists at the facility.
009 GP02.CN Si RICE GM Vortex 5:7L,4SRB,88 0 0 0.0 Cancellation received on 07/16/2020
HP(site rated),SN:13218543
010 GP02.CN SI RICE GM Vortec 5.7L,4SRB,88 0.0 0.0 Cancellation received on 07/16/2020
HP(site rated),SN:13219375 ,
011 GP02.CN SI RICE GM Vortec 57L,4SRB,88 0.0 0.0 Cancellation received on 07/16/2020
HP(site rated),SN:Z628212
012 GP02.CN SI RICE GM Vortec 5.7L,4SRB,87.5 - Cancellation received on 07/16/2020
HP(site rated),SN:Z642338
XA External Combustion Sources 0.2 0.2 1.9 0.1 1.6 0.0 0.2 0.2 1.9 0.1 1.6 0.0 Insignificant Source
XA Fugitives _ 0.2 0.0 0.2 0.0 Insignificant Source
XA Produced Water Tanks _ 0.1 0.0 0.1 0.0 Insignificant Source
FACILITY TOTAL 0.3 0.3 0.0 0.0 28.1 472.3 0.2 25.5 12.3 0.3 0.3 0.0 0.0 6.3 28.2 0.2 10.3 0.8 VOC: Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
CO: True Minor(PSD and OP)
HAPS: Minor n-Hex&Total
HH: Not applicable-area source
7777:Area source
Permitted Facility Total 0.1 0.1 0.0 0.0 26.2 472.2 0.0 23.8 12.3 0.1 0.1 0.0 0.0 4.4 28.1 0.0 8.7 0.8 Excludes units exempt from permits/APENs
. (4)Change in Permitted Emissions -0.2 -0.2 0.0 0.0 -5.9 -39.6 0.0 -11.4 -1.4 Pubcom required because source is attempting to
obtain a federally enforceable limit on the potential
to emit in order to avoid other requirements.
Total VOC Facility Emissions(point and fugitive) 28.4 Facility is eligible for GP02 because<90 tpy
(4)Change in Total Permitted VOC emissions(point and fugitive) -39.6 Project emissions less than 25 tpy
Note 1
Note 2
Page 8 of 9 Printed 11/17/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPS
Company Name POC Enemy.Inc.
County AIRS ID 123
Plant AIRS ID 9F73
Paciito Name J Klein 7 Sec H2
Emissions-uncontrolled(lbs per year)
POINT'PERMIT I Descdpllon ro0memeMae A=•alaenym Acrolein Benzene Toluene Bleaen=eee Xylenes n-Hexane McOH 220Tm?H2O TOTAL
(RP
Previous FACILITY TOTAL 0.4 0.1 0.1 3.1 3.0 0.1 1.7 24.9 0.1 0.1 0.0 0.0 34.3
001 17WE1191 Sateen(16)538 bbl fixed roof 1724.4 2403.5 OUR 1041.0 14248.9 62.7 9.8
condensate storage Vessels
002 GP07 Hydrocarbon Loadout 470.1 4079,5 2.3 _
003 GP02 SI RICE GM Vortec 5.7L,4SRS,08 133.6 10.2 17.I 103 19.9 0.1
HP(site rated),SN:'13218537 ,
004 GP02 SI RICE GM Vortec 5,7L,4SR8,88
HP(site rated),SN: 133.6 18.2 1I:I 10.3 19.9 0.1
I OCHMM411120033
005 GP02.CN ' SI RICE GMVodec 5.71,4SR8,88
HP(site reted),SR: 00
10CHMM503060025
006 GP02.CN SI RICE GM Voles 5,7L,4588,88
HP(site rated),SN: 0.0
10CHMM411120035
007 GP02.CN SI RICE GMVortec 5.7L,4SR8,88
HP(site rated),ON.13218522 0.0
008 GP02.CN SI RICE GM Voles 5 7L,4SR8,63'
HP(site rated),SN: 0.0
10CHMM310030034
009 GP02.CN SI RICE GM Voyles 5,7L,4SR8,88 ,.
HP(elle rated),SR:13218543 00
010 GP02.CN SI RICE GM Voyles 5.7L,45RB 88
0.0.
HP(see rated),SN:13219375
011 GP02.CN SI RICE GM Vortec 5.7L,4SR8,88
0.0
HP(9Jld 41010,SR:2628212
012 GP02 CN SI RICE GMVortec 5.7L,4SR8,87.5
HP(site rated),5N:2642338 0.0
XA External Combustion Sources 0.0
XA Fugitives 8.9 89 55 07 10.0 0.0
XA Produced Water Tanks 9.0 141 (15 55 3,0 0.0
TOTAL(tpy) 0.1 0.0 0.0 1,1 1.2 0.0 0.5 9.2 0.0 0.0 0.0 0.0 12,3
, 'Total Reportable=all HAPs where uncontrolled emissions>de minimus Values
YET Text:unconifolled enliseuu':o.,de n::Nnws
Emissions with controls(lbs per year)
POINTIPERMIT IGescriplion Pa,neamyee ooeuiaenyae Acrolein Benzene Toluene P4poeszene Xylenes n-Hexane McXH .-11"°P H2S TOTAL
Previous FACILITY TOTAL 0.4 0.1 0.1 0.2 0.2 0.0 0.1 1.3 0.1 0.0 0.0 0.0 2.4 •
001 17WE1191 Sateen(16)538 bbl frcetl roof 86.2 120.2 4.4 52.1 712.4 31 0.5
condensate storage vessels _ .
002 GP07 Hydrocarbon Loadout 23.5 204,0 _ 0.1-
003 GP02 SI RICE GM Vortec 5.7L,4SRB,88 I3'i5 16::: I7.1 10.3 t9.9 0.1
HP(site rated).SN:13218537
SI RICE GM Vortex 5,7L,4SR8,88
004 GP02 HP(site rated),SN', 11,0 18.7 17.1 103 19.9 0.1
1 OCH MM411120033
SI RICE GM Votes 5.7L,4008,88
005 GP02.CN HP(site rated),SN: 0.0
I0CHMM503060025
SI RICE GM Vortec 5.7L,4SR8,88
008 GP02,CN- HP(site rated),SN: - 0.0
I0CHMM411120035
007 GP02.CN SI RICE GM Vortec 5.7L,4SR8,88 0.0
HP(site rated),800 5 5 0 18522,
SI RICE GM Vortec 7L,4500,88.
008 GPOZ EN HP(site rated),SN: 0.0
I0CHMM310030034
000 GP02CN SI RICE GM Vodec 5.71.,458888 - bit
HP(site rated),SR:13218543
16543
010 GP02.CN SI RICE GM Voiles 7L,5 4SR8,88. 0.0
HP(site rated),SRI 13219375
017 GP02.CN SI RICE GM Vortec 5.7L,4SR8,88 0.0
HP(sae algid),SN:2628212
51 RICE GM Votes 5,7L,4588,87.5
012 GP02.05- HP(site rated),5N:264233B - 0.0
XA External Combustion Sources 0 0
XA Fugitives 09 09 36 57 10:1 0.0
XA Produced Water Tanks LII 141 1,0 59 0.0
TOTAL(tpy) 0.1 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 0.0 0.0 0.8
9 17WE1191.CP2 11/17/2020
ECE
Condensate Storage Tank(s) APEN JU41 s zap
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40,1 440 Form APCD-205 tart'
5 Ge'4
,. CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and wilt 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: 17WE1191 AIRS ID Number: 123 / 9F73 /001
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: J Klein 7 Sec HZ
Site Location
Site Location:
SWSE Sec 7 T5N R64W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203 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.
433506
COLORADO
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'
Permit Number: 17W E 1191 AIRS ID Number: 123 /9F73/001
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 O 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 O Transfer of ownership' O 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 Et Notes: Requesting new throughput limit and emissions limits for Construction Permit 17VVE1191;
2019 Actual throughput; Emissions calculated using previously approved site-specific emission factors.
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 8/19/2017
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: 0 Exploration&Production(E&P)site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? Yes O No
Is the actual annual average hydrocarbon liquid throughput≥500 bbl/day? 0 Yes ❑ No
If"yes", identify the stock tank gas-to-oil ratio: 0.004197 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) YesNo
805 series rules? If so, submit Form APCD-105. 0 O
Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual i Yes ❑ No
emissions≥6 ton/yr(per storage tank)?
COLORADO
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Permit Number: 17WE 1191 AIRS ID Number: 123 19F73/001
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 294,025 352.830
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 48.6 degrees RVP of sales oil: 7.5
Tank design: 0 Fixed roof O Internal floating roof ❑ External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TK-1 16 8,608 1/2017 8/2017
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 43005 J Klein 7Q-321 O
05 - 123 - 43000 J Klein 7T-121ST ❑
05 - 123 - 43001 J Klein 7T-201 O
05 - 123 - 43002 J Klein 7T-241 O
05 - 123 - 42999 J Klein 7T-301 O
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The E&P Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.40973/-104.58987
Q Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec)
Indicate the direction of the stack outlet: (check one)
❑Upward O Downward O Upward with obstructing raincap
❑Horizontal O Other(describe):
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):
3 COLORADO
Permit Number: 17WE 1191 AIRS ID Number: 123 /9F73/001
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor Size: Make/Model:
❑ Recovery
Unit(VRU): Requested Control Efficiency: %
VRU Downtime or Bypassed (emissions vented): %
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model: 8 x Cimarron 48", 1 x Cimarron 60"
❑ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,342 Btu/scf
Constant Pilot Light: ❑ Yes O No Pilot Burner Rating: MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 30 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
COLORADO
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Permit Number: 17WE 1191 AIRS ID Number: 123 /9F73/001
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):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured
by control equipment) emissions)
VOC Enclosed Combustor 100% 95%
NOx
CO
HAPs Enclosed Combustor 100% 95%
Other:
From what year is the following reported actual annual emissions data? 201 9
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 Units ( '42r Emissions Emissions8 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
VOC 1.9141 lb/bbl ProMax 281.39 14.07 337.67 16.89
NOx 01380 lb/MMBtu TCEQ N/A 155 N/A 1.84
CO 0.2755 ib/MMBtu TCEQ N/A 3.22 N/A 3.82
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes ❑No
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 Emission Factor? Actual Annual Emissions
Abstract - Source Uncontrolled Controlled
Chemical Name Service(CAS) Uncontrolled Units
Basis (AP-42, Emissions Emissions8
Number Mfg.,etc.) •(lbs/year) (lbs/year)
Benzene 71432 O0049 lb/bbl ProMax 1,437.00 71.85
Toluene 108883 0.0068 lb/bbl ProMax 2.002.94 100.15
Ethylbenzene 100414 2.52E-04 Ib/bbi ProMax 74.01(DM) 3.70(DM)
Xylene 1330207 0.0030 lb/bbl ProMax 867_45 4337
n-Hexane 110543 0.0404 lb/bbl ProMax 11.874.07 593.70
2,2,4-Trimethylpentane 540841 1.78E-04 lb/bbl ProMax 52.25(DM) 2.61/DM)
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.
5 COLORADO
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Permit Number: 17WE 1191 AIRS ID Number: 123 /9F73/001
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Sig e of Legally Authorized Person (not a vendor or consultant) Date Sig*t
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
0 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:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
jec COl4Rg0?
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E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: PDC Energy,Inc.
Source Name: J Klein 7 Sec HZ
Emissions Source AIRS ID2: 123/9F73/001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05- 123-43004 J Klein 7Y-201 ❑
05- 123-43003 J Klein 7Y-241 ❑
05- 123-42998 J Klein 7Y-341 ❑
O
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Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212 TK-1 Addendum
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