HomeMy WebLinkAbout20200628.tiffCOLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
October 7, 2020
Dear Sir or Madam:
RECEIVED
OCT 1 2 2020
WELD COUNTY
COMMISSIONERS
On October 8, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
PDC Energy, Inc - Lory 33 Sec HZ. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
Pv b l c Rev; ecAJ
to/19/..-o
cc: PL(TT), HL(DS) PW@M/ER/cH/c ()
OG(3M)
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aoao-O62 .
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc - Lory 33 Sec HZ - Weld County
Notice Period Begins: October 8, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: PDC Energy, Inc
Facility: Lory 33 Sec HZ
Well Production Facility
SWSE quadrant of Section 33, Township 4N, Range 65W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc is changing coverage of twelve (12) 538
barrel fixed roof, liquid manifold storage vessels used for the store of condensate from a GP10 to a
traditional construction permit. PDC Energy, Inc is also changing the coverage of condensate loadout
activities from a GP10 to a traditional construction permit.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• Permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area).
• The source is requesting a federally enforceable limit on the potential to emit in order to avoid
other requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and draft permits of Construction Permit 20WE0566 and
Construction Permit 20WE0567 have been filed with the Weld County Clerk's office. A copy of the draft
permits and the Division's analysis are available on the Division's website at
https: //www.colorado.gov/ pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.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
,
COLORADO
Department of Public
Health Et Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
2,Agoi
COLORADO
Department of Public
Health b Environment
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: 20WE0566 Issuance:
Date issued:
Issued to:
XX/XX/XXXX
PDC Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Lory 33 Sec HZ
123/AOEA
SWSE SEC 33 T4N R65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
1
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-01
002
Twelve (12) 538 barrel fixed roof liquid
manifold storage vessels used to store
condensate
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit 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.cotorado.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
4,1*400i'
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
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.)
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-01
002
---
1.1
10.8
2.3
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.
6. 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.
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-01
002
Enclosed Flare
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
Page 2 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
I I .A.4. )
Process Limits
Facility
Equipment ID
AIRS
Point
Process
Process Parameter
Annual Limit
TK-01
002
01
Condensate Throughput
259,220 barrels
02
Combustion of pilot
light gas
1.1 MMscf
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 II I. 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.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.
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of
95%. If a combustion device is used, it must have a design destruction efficiency of at least
98% for hydrocarbons except where the combustion device has been authorized by permit
prior to March 1, 2020. The source must follow the inspection requirements of Regulation
Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of
two years, made available to the Division upon request. This control requirement must be
met within 90 days of the date that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank
Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section
II.C.2.
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7', Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
16. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (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 OI:tM 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. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence
of visible emissions. "Visible Emissions" means observations of smoke for any period or
periods of duration greater than or equal to one minute in any fifteen -minute period during
normal operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23)
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
Number
Existing Emission Point
New Emission Point
Page 4 of 10
a 44
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
GP10
123/A0EA/001
123/A0EA/002
20. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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.
21. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D)
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
Page 5 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any
express term or condition of the permit. If the Division denies a permit, conditions imposed
upon a permit are contested by the owner or operator, or the Division revokes a permit, the
owner or operator of a source may request a hearing before the AQCC for review of the
Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the
Division in writing requesting a cancellation of the permit. Upon notification, annual fee
billing will terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Diego Chimendes
Permit Engineer
Page 6 of 10
C 44'40
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Page 7 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
002
Benzene
71432
1245.2
62.3
Toluene
108883
1749.4
87.5
Ethylbenzene
100414
12.4
0.6
Xylenes
1330207
658.0
32.9
n -Hexane
110543
11837.5
591.9
2,2,4-
Trimethylpentane
540841
4.3
0.2
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Process 01: Condensate Throughput
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
7.94x10-3
---
TNRCC and Promax
CO
1.58x10-2
---
TNRCC and Promax
VOC
1.666
8.33x10"2
Promax
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health ff Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
71432
Benzene
4.80x10"3
2.40x10"4
Promax
108883
Toluene
6.75x10-3
3.37x10-4
Promax
1330207
Xylene
2.54x10-3
1.27x10-4
Promax
110543
n -Hexane
4.57x10"2
2.28x10-3
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 outlet of the low
pressure separator for the Lory 11N well on 05/26/2020. The NOx and CO AP -42 emission factors (0.1380
lb/MMBtu and 0.2755 lb/MMBtu respectively) were converted to units of lb/bbl using a heat content of 2460.5
Btu/scf, molecular weight of 44.4 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, and a VOC mol%
of 60.9%. Actual emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput.
Process 02: Combustion of pilot light
CAS #
Pollutant
Uncontrolled Emission
Factors
lb/MMSCF
Source
NOx
77.2
AP -42 Chapter 13.5
VOC
6.1
AP -42 Chapter 1.4
Table 1.4-2
CO
352.2
AP -42 Chapter 13.5
Note:
The NOx and CO emission factors listed in the table above were obtained by multiplying the AP -42 Chapter 13.5
NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,136
Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP -42 Chapter 1.4
emission factor by a heat value of 1,136 Btu/scf. Actual emissions are calculated by multiplying the emission
factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a
constant rate of 15.6 scf/hr. There are a total of eight (8) combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 124.8 scf/hr.
6) In accordance with C.R.5. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Page 9 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Operating Permit
Synthetic Minor Source of: VOC, CO, Et NOx. True Minor Source
of HAP
PSD
True Minor Source of: CO a NOx
NANSR
Synthetic Minor Source of: VOC Et NOx
MACT HH
Area/Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
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 For Division Use Only
Review Engineer: Deism miniceir
Package#:
Received Date:
Review Start Date: 3.722.0
Section 01-Facility Information
Company Name: Quadrant Section Township Range
County AIRS ID: " . _ SE 33 44 42,5
Plant AIRS ID:
Facility Name: as __h.N.;
Physical
Address/Location: 5
County: Weld County
Type of Facility:
What industry segment?v.i&.,p. _l.v_ ; y .
Is this facility located in a NAAQS non-attainment area?
If yes,for what pollutant? Coco 'I an
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
Permit#
AIRS Point If
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 initial
.,002 storage Tant, Tait Yes 20V4E05436 I Yes:. 'chance
Section 03-Description of Project
PM Energy,Mc, .Df;,subs—Atha onf,.-.i2. ,sl•`„Ee ssEdds:-r hr e icallownam,conamiteter_ .._Y Monaco t Eder
1011dn.I;f ar,d..3,,tEd anginas. -coin is"Poisit sissrahmlit PesairsIsti_ _ - _tow stesi Ocaltis r ,_sim ear se Stamm ,vl s._ ..._.._. n r r nai
ana>r_s covers rersitlatoi r analysis s and cosi:Mons calearemos 3 Of tospearsaitattatemasapiperemosmnhetBe. . Ica 4432 .gp
06101/2020i
P31s,$30Slrre is Piriesioaquirea because tonstarroPed.V or eleitssi: mod Nividooliad e
than 250 tRr .:.._ _ ,: F _u_Mon
(lRepolarton 3 Part B Svc_
-nee peen-444,4hp Levee:stet tri,ponies emetsemss itesssise reoptes:eid lacitayeside cons:;cleat ims s top
latair redarally: ._ e M000rt __ esi ecin.ct emote irmode Peas t,._ _rc, 3;Mie Lem
t. 7,2 arsine ts -ham oda ancletts. ;.r .s.,
ii
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required?
If yes,why? Otremie ;,. 2y.ans vied
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required?
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 V0C PM2.5 PM10 TSP HAPs
Colorado Aft Permitting Project
Prevention of Significant Deterioration (PSD)
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:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
J
J
❑ ❑
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑
Storage Tank's) Emissions inventory
Section 01- Administrative Information
Facility AIRs ID:
123
County
4000
Plant
062
Point
Section 02 - Equipment Description Details
Storage Tank Liquid
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control Efficiency U:
Limited Process Parameter
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tan(*)
Actual Throughput =
Requested Permit Limit Throughput=
216,017.0 Barrels (bbl) per year
259,220.0 Barrels (hbl) per year
Requested Monthly Throughput= _2013,8 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput =
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquids
produced =
Molecular Weight=
VOC mal°% =
Molar Volume =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
,220.0 Barrels (bbl) per year
2460.5 Btu/scf
scf/bbl
44.4 Ib/Ibmol
79.41 scf/Ibmal
• Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Control Device
12,47.3,4 MMBTU per year
14.30E r,, MMBTU per year
1.1,302_.0 MMBTU per year
124.8 scfh
'711i3e.) Btu/scf
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
16608,60
tag ) 4
to
tee
- 'stt) ,....
Benzene
30 Cli
Toluene
6749E 03
Ethylbenzene
4.795E-05
3 303860,5
Rylene
2.538E-03
n -Hexane
4.567E-02
224 TMP
1.647E-05
..
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
0.00'➢5
- -
t}1)(ta a ._.. '8 -
PM2.5
00075
5Ox
0.0006
NOx
1•.1380
CO
,.3.755
6.5156
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
)Ib/MMBtu) )lh/MMscf)
(Pilot Gas Heat
Combusted)
(Pilot Gas
Throughput)
PM10
_-0075
8.5
'i0 x41/1'4c
lf} 0j✓: n
40 '2 si
,2 T .1 102:
PM2.5
6.L'0,5
8.5
SOx
0.0006
NOx
0.0680
VOC
0.0054
_
CO
0.3100
..
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(Ibs/month)
PM10
PM2.5
SOx
NOx
VOC
CO
0.1
0,_
_.
....
10.2
.,._
„._
__
__.
10.2
0.:,
0.0
.r..,
0.0
. _.
0.5
1.1
0.9
_..,
1.3.
_._
13;.9
216,0
100.0
JO
216.0
__ 3
1830.0
2.3
1.9
1.9
2.3
2.1
382.2
3 of 9
K:\PA\2020\20WE0566.CP1
✓torage Tanks; Emissions
ns
Hazardous Air Pollutants...
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
)Ibs/year) (Ibs/Year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224TMP
1.45.2
1977.:
5'1,9
1245.2
.._._
1749:4
14573
72,9
1749.4
._._
10.4
4.5
17.4
651`-
148.4
27.4
154.5
._..
119374
9164:9
493.2
_1337.9
}..,�
0.7
_,3
4 of 9 K:\PA\2020\20WE0566.CP1
Storage -1 i_ Emissions Ali :(rd
Section 09 - SCC Coding and Emissions Factors (For Inventory Use Only)
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Souare r„quires a permit
Regulation 7, Part D,Section I.C, D, E, F
Storage., lea is subject . -.. Prartion IC F
Regulation 7, Part D,Section I.G, C
Storage Tank :s not ssF, 7, on I.G
Regulation 7, Part D,Section II.B, C.1, C.3
Storage to --k is subl ut ,,. epee ID,:,,,.. , 79,1100 II 0, Ca . Cal
Regulation 7, Part 0,Section II.C.2
Storage tar, c is subject to Aacelat' an 7, Part O, Section II. C.2
Regulation 7, Part D,Section II.C.4.a.(i)
Storage To is is not sullied to Regatta -bon 7, Par D, Section ii.C..a.s=
Regulation 7, Part D,Section II.C.4a.(ii)
Storage Wank is not subject to 3a ,__o" 7. Part D. Section II.Crisai in e -;
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is notsuhlect to TOPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage tank is net subject to . -:;P5 OC,DCP.
NSPS Subpart OOOO0
Storage Innis snot subject to SPS 000X'
Regulation 8, Part E, MACT Subpart HH
Storage tone is riot subject to MAU H}i
(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? Hfo
If yes, are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tans VOC per year OR are the
uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted (for produced water tanks, a pressurize liquid sample must be analyzed using flash liberation analysis)? This sample
should be considered representative which generally means site -specific and collected within one year of the application received
date. However, if the facility has not been modified (e.g., no new wells brought on-line), then it maybe appropriate to use an
older site -specific sample. Yes
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company request a control device efficiency greater than 95% for a flare or combustion device? Ne
If yes, the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08 - Technical Analysis Notes
1. Site -specific Emission Factors: The site specific sample used to establish emissions factors for this source was obtained within a year of the application. The sample was obtained from the Cory 11N well. This well is
one of the twelve new wells drilled at this facility. As a result, the permit will not require initial testing in order to sbtain a 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 Typically, the secondary Combustion emissions are calculated using the waste gas flow rate and heat content predicted by the model used to establish the site -specific emissions factors. Based on
the ProMax simulation the total waste gas flow rate was predicted to be 0.01081142 MMscf/day (Flash and W&B gas) and heat content: 2460.49 Btu/scf. Using this information, the yearly heat input of the gas would
be calculated as follows:Heat Input (MMBtu/yr) =(0.01081142 MMscf/day)•(365 day/year)`(2460.49 MMBtu/MMscf)= 9709.51 MMBtu/year. Using this value, the NOx and CO emissions would be calculated at
0.67 tpy and 1.34tpy respectively. - -
2.2 Operator used the following equation to calculate the annual heat input.
Heat Input (MMHtu/yr) _ [Uncontrolled VOC (tan/yr)] a [2000(lb/ton)] =MW (lb/lbmol) a [379.41(scf/lbmol)] o [1/VOC mol 96] n [Heat Content (Btu/scf)] n [1MMBtu/(1000;000 Btu)].
The values used in the equation are as follow: (i) Molecular weight: 44.4 Ib/lbemol, (ii) VOC wt %:60.88%, (iii) Heat Content: 2460.49 Btu/scf. Using these values, the operator calculated a heat input of 12,423.4
MMBtu/yr. Since this value is more conservative than the value calculated above using prescribed methods, it will be used for permitt ing purpose.
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 cant n initial or periodic
opacity testing for the enclosed combustor(s) because the O&M plan approved for this source requires weekly visible emissionsobservations of the enclosed combustor(s).
A throughput limit is included in the permit for pilot combustion. Emission factors and calculation methods for pilot light c ombustion emissions are also included in the notes to permit holder. This
information is included in the permit because pilot light emissions contribute to the overall emissions from this source. Addtionally it is important to include this information because throughput tracking and emission
calculation methods are different than those used to estimate emissions based on the condensate throughput. This clarity is inporant for accurately quantifying actual emissions at this facility.
4. A permit draft copywassent to the operator for review. On 09/30/2020, operator informed they had nocomments on the permitdraft.
AIRS Point ll
Process it SCC Code
01 11 #'fixed.
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 ;. _ _ lb/1,000 gallons Condensate throughput
PM2.5 ;.0_ 0 lb/1,000 gallons Condensate throughput
SOx 9+_,. _ lb/1,000 gallons Condensate throughput
NOx x..≥_ „ lb/1,000 gallons Condensate throughput
VOC 39.„€ 95 lb/1,000 gallons Condensate throughput
CO .._ - lb/1,000 gallons Condensate throughput
Benzene _.. lb/1,000 gallons Condensate throughput
Toluene » lb/1,000 gallons Condensate throughput
Ethylbenzene .._.. lb/1,000 gallons Condensate throughput
Xylene 0 DP lb/1,000 gallons Condensate throughput
n -Hexane s._s lb/1,000 gallons Condensate throughput
224 TMP 0.9C lb/1,000 gallons Condensate throughput
5 of 9
K:\PA\2020\20WE0566.CP1
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B -APEN and Permit Requirements
in the Elorlirkttairtiniimi A=na
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from thls individual source greater than 2TPY lRegulation 3, Part A, Section li.D.1.a)?
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Aretoral facility uncontrolled VOL emissions greater than 5TPY, NO4 greater than 10TPY or CO emissions greater than 10 Tel )Regulation 3, Part 5, Section 11.0.3)?
NON -ATTAINMENT
1. Are uncontrolled emissions front any criteria pollutants from this individual source greater than S TPY (Regulation 3, Part Ai, Section ll.O.I.a)?
2. Is theconstruction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Are total facility uncontrolled TOT emissions greater than 2TPY, Nun greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)7
'court, requic.,,. pewit
Colorado Regulation], Part 0, Section I.C-F &G
1. Is this storage tank located in the g -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D, Section IA.11?
2. Is thisstorege tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water ANOthat are looted at or upstream of a natural gas processing plant (Regulation 7, Part 0, Section IA.11?
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part 0, Section 1.0)?
4. Ooesthis storage tank contain condensate?
5. Does this storage tank exhibit"Flash" (e.g. storing non -stabilized liquids)emissions (Regulation 7, part D, Section 1.0.2)7.
6. Are uncontrolled actual emissions of this storage tank equal to or greater than atone per year VOC (Regulation 7, Part 0, Section i.D.3.a(R)1?
!Source Requires an APEN. Go to
Part 0, Section 1.C.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Part 0, Section 1.0.2— Emission Estimation Procedures
Part 0, Section 1.0 — Emissions Control Requirements
Pert 0, Section 1.E —Monitoring
Part Cr, 5ectlan 1$ — Recordkeeping and Reporting
hiew9 Piewilatipi,unction: G
Part CI, Section I.G.2- Emissions Control Requirements
Part 0, Section i.GI.e and b —General Requirements for Air Pollution Central Equipment —Prevention of Leakage
Colorado Regulation 7. Part D. Section II
I. Is this storage tank located eta transmission/storage facility?
2. Is this storage tanks located at an oil and gas exploration and production operation, well production facility', natural gas Compressor stations or natural gas processing plant°(Regulation 7, Pat 0, Section P.ci?
3. Does this storage tank have a fixed roof (Regulation 7, Part 0, Section 11.0.201?
4. Are uncontrolled actual emissions of this storage tank a ual to or greater than 2 tons per year VOC (Regulation 7, Part D, Section tt.Ct.c)?
Part 0, Section 11.B —General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part 0, Section II.C.1 - Emissions Control and Monitoring Provisions
Part D, Section II.C.3 - Recordkeeping Requirements
5. Does the storage tank contain only "stabilized" liquids (Regulation 7, Part O, Section il.C2.b)?
Ycd,.1%
resS N
yes»..,-;st
Part 0, Section 11.0.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after May 1,2020 or located ate facility that was modified on or after May 1, 2020, such
6. that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part 0, Section ll.C4.a.(4?
Is the controlled storage tank located at a well production facliy, natural gas compressor station, or natural gas processing plant constmcted on or after January1, 2021 or located at a facility that was modified an or after /actuary 1, L .
7. 2021, such that an additional controlled storage vessels constructed to receive an anticipated increase In throughput of hydrocarbon liquids or produced water (Regulation 7, Part 0, Section ilC.9.aRi)?
40 CFR. Part 60. Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. is the individual storage vessel capacity greater than or equal t075 cubic meters (ms)[`472 BMA (40 CFR 60.11ob(a))?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.879 m° (-10,000 BBL] used for petroleum' or condensate stored,processed, or treated priorio custody transfer' as defined in 60.111h?
3. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984(40 CFR60.11obia)]?
4. Does the tank meet the definition of "storage vessel"' in 60.111b7
5. Does the storage vessel snore a "volatile organic liquid(VOL)"sffi defined In 60.1116?
6. Does the storage vessel meet any one of the following additional exemptions:
a. B the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa 1'29.7psi) and without emissiansta the atmosphere 160.110b(d)(2))t or
b. The design capacity is greaterthan or equalto 151 n1'1 -950B01] and stores a liquid with a maximum true vapor pressures lessthan 3.5 kPa 160.1106)6))7; or
c. The design capacity Is greater than or equal to 75 M' (-472 BBL] but less than 151 m' (-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11Db(b))?
7. Does the storage tank meet either one of the following exemptions from control requirements:
a. The design capacity is greater than or equal to 151 nis (-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 kPe?l or
b. The design capacity is greater than or equal to 75 Mt 1-472 BBL] but. lessthan 151 ma 1-950 BBL] and stores a liquid wnha maximum true vapor pressure greater than or equalto 15.0 kPa but lessthan 27.6 kPa?
Go to next question
Source Requires a permit
Source Requires an APES. G0 to
Go to next question
Source Requires a permit
Continue - You have Indicated th
Continue - You have indicated th
storage Tank is not subject to Re
Continue -You have indicated th
Go to the next question - You he
Go to the next question
Source's subject to parts of Regr
Go to the next question
Storage Tank is not subject NSPS
I
90 CFR, Part 60, Subpart 0000/0000a, Standards of Performance for Crude 00 and Natural Gas Production, Transmission and Distribution
1. Is this storage vessel located at a facility in the onshore oil and natural gas production segment, natural gas processing segment or natural gas transmission and storage segment of the industry?
2. Was this storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015?
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 15, 2015?
4. Are potential VOC emissions' from the individual storage vessel greater than or equalto 6 tons per year?
5. Does this storage vessel meet the definition of"storage vessel"' per 60.5430/60.5430a?
6. Isthestora a vessel subect to and controlled in accordance with requirements for stmage vessels in 40CFR Part 60 Sub art Kb or 90 CFR Part 63 Sub art HH7
(Note: If a storage vessel is previously determined to be subject to NSPS 0000/0000e due to emissions above 6 tans per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per
60.5365]e)(2)/60.5365a(e)(2) even H potential VOL emissions drop below 6 tons per year]
90 CFR. Part 63. Subpart MALT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an all and natural gas production facility that meets either of the following criteria:
a. Afacility thatprocesses, upgrades or stores hydrocarbon liquids' (63.760(a)12)); OR
b. Afacility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gastransmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank looted at a facility that is majorsf0r HAPs7
3. Does the tank meet the definition of "storage vessel"° in 63.7617
4. Doesthetank meet the definition of"storage vessel with the potentlalfor flash emissions' per 63.761?
5. Is the tank subject to control requirements under40 CFR Part 60, Subpart Kb or Subpart 0000?
Subpart A, General provisions per A63.764 (a) Table 2
063.766- Emissions Control Standards
§63.773 -Monitoring
§63.774-Recordkeeping
463.775 -Reporting
PACT Review
RACE review is required If Regulation 7 does not apply AND if the tank is In the noreattainment area. If the tank meets both criteria, then review RACF requirements.
Disclaimer
WalaVn
DerititiVtIgi
Continue - You have Indicated th
Storage Tank B not subject NSPS
Ga to the next question
Storage Tank Is not subject NSPO_
Continue - You have Indicated th
Storage Tank Is not subject MAC •
This document assists operators with determining applicability a/cartein requirements of the Clean Air AR, its implementing regulations, and Air Quality Control Commission regulations. This document is not
a rule or regulation, and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change or substitute for any law, regulation,
or any other legally binding requirement and is not legally enforceable. In the event of any conflict between thelanguage 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 ofnan-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 end ofitself.
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
AOEA
Lory 33 Sec HZ
History File Edit Date
10/1/2020
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons oer year
EMISSIONS With Controls (tons oer 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
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Previous Permitted Facilit
total
0.0
0.0
0.0
0,0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
GRID ': '
12-538 bbl Condensate Tanks
-
0.0
0.0
Permitted under point 002
Condensate Loadout
0.0
-
0.0
Permitted under point 003
2-410 bbl & 9-400 bbl Produced Water
Tanks
0.0
0.0
Permitted under point 004
RICE 4SRB Caterpillar M: G3306NA
0.0
0.0
Permitted under point 005
RICE 4SRB.Caterpillar M: G3306NA
0.0
0.0
Permitted under point 006
RICE 4SRB Caterpillar. M: G3306NA
0.0
0.0
Permitted under point 007
RICE 4SRBCaterpillarM: G3306NA
0.0
0.0
Permittedunder point 008
RICE 4SRB Cummins,. M: GTA855
0 0
0.0
Permitted under point 009
RICE 4SRB PSI M: 1.4 6L.
0.0
0.0
Permittedunder point 010
Well Unloading. and Maintenance
-
0.0
-
0.0
002
20WE0566
12-538 bbl Condensate Tanks
1.1
216.0
2.3
7.8
1.1
10.8
2.3
0.4
Point added and updated on 09/02/2020
003
20WE0567
Condensate Loadout
0.2
30.6
0.3
0.5
0.2
1.5
0.3
0.0
Point added and updated on 09/02/2020
004
GP08
2-410 bbl & 9-400 bbl Produced Water
Tanks
0.0
3.0
0.1
0.5
0.0
5.9
0.1
0.0
Point added and updated on 09/02/2020
005
GP02
RICE 4SRB Cummins M: G855 SN:
25423569
0.1
0.1
10.1
3.3
45.8
0.2
Di
0.1
1.7
1.2
3.4
0.2
Point added and updated on 09/02/2020
006
GP02
RICE 4SRB Caterpillar M: G3306NA SN:
GX09165
0.1
0.1
18.6
0.9
18.6
0.4
Di
Di
1.3
0.9
2.7
0.4
Point added and updated on 09,02/2020
007
GP02
RICE 4SRB Caterpillar M: G3306NA SN:
GX09016
0.1
0.1
18.6
0.9
18.6
0.4
0.1
0.1
1.3
0.9
2.7
0.4
Point added and updated on 09/02/2020
008
GP02
RICE 4SRB Caterpillar M: G3306NA SN:
GX08747
0.1
0.1
18.6
0.9
18,6
0.4
0.1
0.1
1.3
0.9
2.7
0.4
Point added and updated on 09/02/2020
009
GP02
RICE 4SRB Cummins M: GTA855 SN:
25328405
0.1
0.1
0.0
26,3
3.1
6.3
0.3
0.1
0.1
0.0
2.2
1.5
4.3
0.3
Point added and updated on 09/02/2020
010
GP02
RICE 4SRB PSI M: 14.6L SN:
EEZOG501863
0.2
0.2
0.0
40.1
3.1
67.5
0,6
0.2
0.2
0.0
4.4
3.1
8.9
0.6
Point added and updated on 09/02/2020
0.0
0.0
XA
External Combustion Devices
0.3
0.3
0.0
3.6
0.1
3,0
0.0
0.3
0.3
0.0
3.6
0.1
3.0
0.0
Insignificant Source
XA
Fugitives
0.3
0.0
0.3
0.0
Insignificant Source
XA
Santrap Drain Tank
0.3
0.0
0.3
0.0
Insignificant Source
XA
Pneumatic Controllers
8.2
0.1
8.2
0.1
Insignificant Source
0.0
0.0
FACILITY TOTAL
0.7
0.7
0.0
0.0
137.2
270.5
0.3
181.2
11.2
0.7
0.7
0.0
0.0
17.1
35.4
0.3
30.2
2.8
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Minor/Syn Minor (PSD/OP)
HAPS: Minor B, T, X, HCHO & Total
HH: Area
7777: Area
Permitted Facility Total
0.5
0.5
0.0
0.0
133.6
261.9
0.0
178.2
11.1
0.5
0,5
0,0
0.0
13.5
26.9
0.0
27.2
2.7
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.5
0.5
0.0
0.0
13.5
26.9
0.0
27.2
2.7
Public Comment required because facility is a
new syn-minor facility and emission increase of
25 tpy of VOC and CO. Modeling not required
based on increase in emissions.
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)
35.7
Facility is eligible for GP02 because CO< 90 tpy
and NoxNOC a 45 tpy.
Project emissions less than 25/50 tpy
26.9
Note 2
Page 8 of 9
Printed 10/1/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY-HAPs
Company Name POO Enemy, Inc
County AIRS ID 125
Plant AIRS ID AOEA
Facility Name Loru 33 Sec HZ
Emissions - uncontrolled (Ibs per Bear
POINT PERMIT Description
3mnIaOld!
Aeemaebya=
Acralein
Benzene
Toluene
EOMbenzeoa
Xylenes
n -Hexane
McOHTN,
H2S
TOTAL
Oovl
Previous FACILITY TOTAL
0.0
0.0
00
0.0
00
0.0
00
00
00
, 0.0
00
00
00
001
GP10.
12-538bblCondensate Tanks
- 0.0
Condensate Load°.
00
2-410 bbl 9-400 bbl Produced Water
Tanks
00
RICE 4SRB Caterpillar M. G3306NA
0.0
RICE 4000 Caterpillar M: G3306NA
00
RICE 4SRB Caterpillar M: G3306NA
00
RICE 4S0B Caterpillar M: 03306NA
00
RICE 4SRB Cummins M GTA855
0.0
RICE4SRB PSI M: 14.6L.
00
Well Unlualna and. Maintenance
00
002
20WE0566
12-538 bbl Condensate Tanks
12452
1749.2
124
6580
11837.5
43
7.8
003
20WE0567
Condensate Loadout
1078
935.8
0.5
004
GPO8
2-410 bbl 89-400bbl Produced Water
Tanks
1966
228.3
4.3
43.0
529.0
0.5
005
GP02
RICE 4SRB Cummins M: G855SN:
25423569
274.7
374
352
2'12
41.0
0.2
006
GP02
RICE 4SRB Caterpillar M: G3306NASNI,
5X09165
714.2
319
301
18.1
35,0
04
007
GP02
RICE 45R B Caterpillar M: 53306NA SIC
5009016
714.2
3I.9
30.1
15,1
350
0,4
008
GP02
RICE 4500 Caterpillar M: G3306NA SN:
5X03747
714.2
3'1.9
''30.1
10I
35.0
0.4
009
GP02
RICE 4SRB Cummins M: GTAS555N:
25328405
376.8
51.3
483
290
56'.'3
0.3
010
GP02
RICE 4SRB PSI NI: 14.6LSN:
EEZOG501863
7442
1013
95.5
574
111.1
0.6
00
XA
External Combustion Devices
0.0
XA
FUOitives
120
1^_0
110
117
13.5
0.0
XA
0011,00 Drain Tank
3.2
14.5
0.0
XA
Pneumatic Controllers
30.1
30,5
I.'
89
'141 I
01
00
TOTAL (tevl
1.8
01
01
0.9
10
0.0
0.4
8.7
02
0.0
00
00
11.2
Total Reoodable = all HAPs where uncontrolled emissions s de 0101025 values
Red Text, uncen's5led Or lissium. ti de n:inlmus
Emissions with controls (Ibs per Bear
POINT PERMIT Desenptien
rumaleooss
Aceuidebvae
Acrolein
Benzene
Toluene
Elnolbenzene
Xylenes
n-Hexano
McCH
0^ TIAP
H25
TOTAL
O
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
00
0.0
00
00
an
0.00
001
GP10 .1:.
12-538 bbl Condensate Tanks
00
Condensate Loadout
0.0
2-410 bbi 8, 9-400 bbl Produced Water
Tanks.
00
RICE 45R6 Caterpillar M 53306NA •
00
RICE 4SRB Caterpillar: IN: O3306NA
00
RICE 4SRB Caterpillar M: O3306NA
00.
RICE 4SRB Caterpillar M: 03306NA
0.0
RICE4SRB Cummins M: GTAB55
00
RICE 4SRB PSI At 14.6L
00
Well Unloadin0 and Maintenance
00
002
20WE0566
12-538661 Condensate Tanks
623
675
329
5919
.._
0.4
003
20WE0567
Condensate Loadout
-
46.8
00
004
GP08
2-410 bbl 89400 bbl Produced Water
Tanta
98
Ito
,._
I
26.4
0.0
005
GPM
RICE 4S0B Cummins M: GB55 SN:
25423569
274.7
314
35^_
212
41.0
0.2
006
GPM
RICE 4SRB Caterpillar M: G3306NASN:
5X09105
688.6
3I9
301
18.1
75.0
0.4
007
GP02
RICE 4S B Caterpillar M: G3306NA 6N:
5X09016
688,6
31.9
30.1
181
350
0.4
000
GP02
RICE 4SRB Caterpillar M: G3306NA 5N:
5008747
688.6
3'1.9
90.1
18.1
350'
04
009
GP02
I
RICE 4SRB Cummins M. GTA655SN:
25328405
376.8
5'1.3
46.3
29.0
56.3
0.3
010-
GP02
RICE 4SRB PSI M: 14.6E SN:
EEZOG501863
744.2
101.3
955
57.4
1111
06
CO
XA
Extemal Combustion Devices
0.0
XA
Fugitives
120
120
11.6
11.7
135
0.0
XA
Santrap Drain Tank
32
14.8
00
XA
Pneumatic Controllers
30.1
:Las
1,7
89
1411I
0.1
0.0
TOTAL (1021
1.7
0.1
0.1
0.1
01
0.0
0.0
0.4
0.2
0.0
0.0
0.0
2.8
20WE0566.CP1
10/1/2020
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: 20WE0567 Issuance:
Date issued:
Issued to:
XX/XX/XXXX
PDC Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Lory 33 Sec HZ
123/AOEA
SWSE SEC 33 T4N R65W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
1
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
LOAD -1
003
Truck loadout of condensate by
submerged fill.
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit 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 more; (iii) does not complete construction within a reasonable time of the
Page 1 of 10
Cri,..%
COLORADO
Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section I I I. F.4. )
3. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Tons per Year
Emission
Type
LOAD -1
003
---
---
1.5
---
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.)
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
LOAD -1
003
Enclosed Flare
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)
Page 2 of 10
44 -:-
COLORADO
Air Pollution Control Division
Department of Public Health & Environment_
Dedicated to protecting and improving the health and environment of the people of Colorado
Process/Consumption Limits
Equipment ID
AIRS
Point
Process Parameter
Annual Limit
LOAD -1
003
Condensate
259,220 barrels
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.1. Et 4.)
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
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.
Page 3 of 10
COLORADO
Air Pollution Control Division
Department of Public Health Et Enveonment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
• 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.
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 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
17. 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 your 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
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/AOEA/001
123/AOEA/003
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:
Page 5 of 10
6<to
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For sources emitting less than 100 tons per year, a change in actual emissions
of five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in
ozone nonattainment areas emitting less than 100 tons of VOC or NO. per
year, a change in annual actual emissions of one (1) ton per year or more or
five percent, whichever is greater, above the level reported on the last APEN;
or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted.
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. 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
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
Page 6 of 10
4;0 -
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
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: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance
Date
Description
Page 7 of 10
Ntio
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Page 8 of 10
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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:
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
107.8
5.4
n -Hexane
110543
935.8
46.8
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:
Pollutant
CAS #
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
VOC
2.36x10"1
1.18x10"2
CDPHE - PS
Memo 14-02
n -Hexane
110543
3.61 x 10.3
1.81 x 10"4
CDPHE - PS
Memo 14-02
Note: The controlled emissions factors for this point are based on the enclosed combustors control efficiency of 95%.
The VOC and HAP emission factors reflect the state default emission factors listed in PS Memo 14-02 for
condensate.
Page 9 of 10
ebt:gif
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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: V0C, CO, Et N0x. True Minor Source
of HAP
PSD .
True Minor Source of: CO a N0x
NANSR
Synthetic Minor Source of: V0C Et N0x
MACT HH
Area/Major Source Requirements: Not Applicable
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecf /
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Colorado Air Permitting Project
Weld County
Exploration & Production Weil Pad
thank 250 Spy,. (Regulation 3 Part A Section 11.6.3.) Point source is permit
(Regulation 3 Part B Section 11.0.2.)
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
For Division Use Only
Review Engineer:
Package#:
Received Date:
Review Start Date:
Diego Chimendes
431279
672'2525
7123/2020
Section 01- Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: AOEA
Facility Name: Logy 33 Sec HZ
Physical
Address/Location:
County:
Type of Facility:
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 hNOx isle-CCJ'
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
003
Liquid Loading
LOAD -1
Yes
vtVE0567
1
Yes
Permit #r?itle'
Issuance_
Quadrant
Section
33
Township
Range
65
Section 03 - Description of Project
PDC Energy, Inc. submitted to ther Division ri'rE`is to permit several sources located at the to, 3a Sec HZ facility. Package contained applications to permit
condensate tank battery (traditional construction permit), produced water tank battery (GPO), condensate loadout (traditional construction permit), and six (6)
RICE 45RB engines (GP02s). This preliminary a=nalysis will cover emission calculations and regulationapplicability of condensate loadout onerat,ons.
Point source is APEN-required because uncontrolled VOC emissions are greater than 1 tpy and uncontrolled emissions of t least onenon criteria pollutant is greater
uired because uncontrolled facility -wide VOC emissions are greater than 2 tpy.
This point source is subject to public comments because requested facility wide controlled emi rims of V0C is greater than 25 tpy and 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 II=.C.i.a. &
Point source is not subject to ambient air imp analysis. (Regulation 3 -Part D Section II A.44)
Sections 04, 05 & 06 - For Division Use Only
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic fv3nr Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? i n
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:
Prevention of Significant Deterioration Ipso)
No
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Colorado Air Permitting Project
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:
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
❑ J ❑ J ❑ ❑ ❑ ❑
SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
❑ ❑
yr :cc i bon Loadout Em;ssior?_ ll?'.et?tocy
Section 01 -Administrative Information
Facility AIRs ID:
Plant
0D3
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
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 =
216.A37 Barrels (hbl) 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 =
Molecular Weight=
VOC mol% =
Molar Volume =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
6 Barrels (bbl) per year Requested Monthly Throughput=
H Barrels (bbl) per year
2460,49 Btu/scf
I.S. ,r:• scf/year
SSSCSn scf/year
scf/bbl
44;4 Ib/Ibmol
60:8R%
378.41 scf/Ibmol
Potential to Emit (PTE) heat content of waste gas routed to combustion device=
MMBTU per year
' MMBTU per year
MMBTU per year
Control Device
Pilot Fuel Use Rate:
Pilot Fuel Gas Heating Value:
15,6 scf),
1136 Btu/scf
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?
Pilot Light Emissions
VOC
Benzene
Toluene
Ethylbenzene
Xylene
Pollutant
Hydrocarbon Loadout
(lb/bbl)
(Volume Loaded)
Uncontrolled
(Ib/bbl)
Uncontrolled
(Ib/MMBtu)
Uncontrolled
(Ib/MMscf)
(Pilot Gas
Throughput)
(Waste Heat Combusted)
0.1 MMscf/yr
155.2 MMBTU/yr
Emission Factor Source
Emission Factor Source
PM10
:002
8.4643
Barrels (bbl) per month
3 of
K:\PA\2020\20WE0567.CP1
Hydrocarbor i_oadout Emissions Inventory
PM2.5 9.:075 8.4643
50x 0..0006 0.6682 1,4-2(5OxJ
N0x 0.06 ; 77.2 Ee;V0C 0:007`.1v 6.1 „IA-2 L0 0,
Co 0.31.044.,,,44,1,:n, 352.2 M � 4E
•
4 of 6 K:\PA\2(120\20W E0567.CP1
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
Irons/year)
Actual Emissions
Uncontrolled Controlled
Itans/year) Itons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/yearl (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM30
PM2.5
50x
NOx
VOC
CO
.._
..
._
_.
..-
_
..
-.
..
_
...
...
..
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) Ilbs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/yearl
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane....
224 TMP
... ,.
.
..
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
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. Secondary Emissions Calculation: Operator used the following equation to calculate the annual heat input.
Heat Input (MMBtu/yr) _ [Uncontrolled VOC (ton/yr)] + [2000(!6/ton)] _. MW (1b/lbmo)) e [379.41(scf/)bmol)] a [1/VOC mol %] + [Heat Content (Btu/scf)) a [1MMBtu/(1000,000 Btu)]
Promax simulation results using the sample obtained from the Loop 11N well was used to calculate the heat imput from loadoutoperatlons. Values used in the equation are as follow: (i) Molecular weight:44.4 [Ii) VOC wt %: 60.88%, )iii
Content: 2460.49 Btu/scf. Using these values, the operator calculated a heat input of 1,759 MMBtu/yr.
at
2. Pilot Light Emissions Calculations: Operator assumedpilot fuel to have the same conditions of field gas which is consistent with the plant design provide by o perator. The permit will not contain pilot light fuel consumption limit because (i)NOx and CO are
not reportable and (II) VOC emissions from pilot light combustion make up less than 1% of the total VOC emissons.The permit will not contain initial or periodic opacity testing for the enclosed combustor(:) because the O&M plan approved f orLids source
requires weekly visible emissions observations of the enclosed combustor(s).
3. L.oadout activities have a decicated enclosed flare and NOx and CO emissions are below reporting levels. For that reason, the permit all not contain NOx and CO limits.
4. On 09/21/2020 a permit draft was provided to the operator for review. On 10/01/2020, operator provided comment regarding fie equipment's description. Equipment description has been adjusted to depict the correct setup. ,.
Section 09 - 5CC Coding and Emissions Factors IFor Inventory Use Only)
AIRS Point #
003
Process #
01
KC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 .. lb/1,000 gallons transferred
PM2.5 lb/1,000 gallons transferred
SOx _ lb/1,000 gallons transferred
NOx lb/1,000 gallons transferred
VOC lb/1,000 gallons transferred
CO lb/1,000 gallons transferred
Benzene lb/1,000 gallons transferred
Toluene .. Ib/1,000 gallons transferred
Ethylhenzene _ . lb/1,000 gallons transferred
Xylene lb/1,000 gallons transferred
n -Hexane .. lb/1,000 gallons transferred
224 TMP lb/1,000 gallons transferred
5of6
K:\PA\2020\20WE0567.CP1
Hydrocarbon Loadaut Regulatory Analysis Worksheet
The regulatory requirements below ore determined based on requested emissions and throughput.
[I d -AM and Pemiit Requirements
ATIAITYINDIT
1 Are uncontrolled actual emissions any individual source greater than 1TP1'(Regulation 3,Part A,Section ITT Lai?
Is the loadout located at an exploration and
criteriae '
and poduce°,siie.g well pad) 3,Part B,Section 11.0.1.1(?
he loadout operation loading less than 10,000 gallons(238 BBLe of crude oil per day on an annual average basis}
A. Is thelbadout operation loading less than 8,]50 bbls per year ofmrdensae via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
Are totalfacility u eolldV an S greaterthan 10,8 w CO emissions greater than 10 TNfReguato 3,Part 3,Section 03)?
NONATTAINMENT
1. Are ruled emissions from any criteria ctis from the ,than l TPy(Regulab 3,Pzr1A,5 bon 11.0.1.x1} so to nett question.
2. Is the loadout located at an exploration and production site(e.g we pace(Regulation 3e Part e section 11.0.1.11} X:.�.., Go o the next question
is the oadout operation loading less than 30,080 gallons 1238 BBe]of wde oil per day an an annual aveage basis?4. next
4. Is the loadout operation loading less than,350 16,308 bbls per year of ls per year of cndensate ondensate via sub fill? H.... Go to next question
5. sty uncontrolled
Ceion loadng mien SS 300bhs condensate god fill emissions
ertlon
S. A Ifacliryu did. emissions from the greater than z,TPYN xgreater thanes TPYgrcO em ss'onz greater than 10 ITTmiliRegulaton 3,Part.,Section 1.0.2)} Yw. s TM loadout requires a permit
Colorado Regulation 7 part Section 11
this condensate storage tankhydrocarbon liquids load loadout located at a well production fablity,natural gas compressor staler nature gas plant? next clo.tion.
2 the ItyM1 h fhyd h M1dJ N equal to 5000.barrels}o, Source ssub7ect to Regulation]Part CISeceon II.C.5.
.S.e..Section Ichedule
Section TCS.a.(i)-egmration ithoutV
.a.[k-0 withoutt Operation
Section Il.c.3 a.liiil-t ut Equlpm and Maintenance
Section II C.a.livl�Lwedout observations and Operator Trzin rig n
Section 5 a.lvl-Records
Section II.C..a.Nil-Requirements for Air Pollution Control Equipment
Disclaimer
This document assists operators with determining applkeblliy of certain requirements of the Clean PsAcr,its?mplern enrlrg reguletnrs,,and Air Quality Control Commission regulations..This document is not e
rule orregelation,and the analysis it contains may not applyfo a partkulersduation based upon the Indeedual facts end circumstances.This document doaa not change orsubatiturelcrany lazy,regulation,or
any other legally birxb'rg requirement and is not legally enforceable.In the event of any contict between the language of this docurnrnt and the language of the Glean Al-Act„its Implementing regulations,
and Air quality Control Comm/swan regulations,the language d the statute or regulaton will control.The used non-mendatory language such as M1ecommend'.'may,""should,."end'Pen,"is intended to
describe PPM interpretations and recommendation.Mandatory knnlnolgy such as"must"and"requimd'are intended to describe controlling requrements under the terms o}the Glean AirActand Air
Quality Control Commission regulations,but this document does not establish legally bindrg mgisremonts is and Aitsed.
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:
C6)6 6 AIRS ID Number: 123 / A0EA / t o Z
miess APCD has dtready assigned a permit and reRS d�=_
Section 1 - Administrative Information
Company Name': pDC Energy, Inc.
Site Name: Lory 33 Sec HZ
Site Location: SWSE Sec 33 T4N R65W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Jack Starr
Phone Number: (303) 860-5800
E -Mail Address2: Jack.Starr@pdce.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt appear
on all documents issued by the APCD. My 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.
lihiForm APCD-2O5 - Condensate _Sor e alters: APEN
Rpvi
(COLORADO
R N6aal
Permit Number:
AIRS ID Number: 123 / A0EA /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
El Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
OR -
▪ MODIFICATION to existing permit (check each box below that applies)
O Change in equipment ❑ Change company name3
O Change permit limit 0 Transfer of ownership4 ❑ Other (describe below)
OR -
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info 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:
Condensate Storage Tanks
TK-1
3/4/2020
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation:
Storage tank(s) located at:
24 hours/day 7 days/week 52
17 Exploration a Production (E&P) site
weeks/year
0 Midstream or Downstream (non EEtP) 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
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
0
Yes
■
No
If "yes", identify the stock tank gas -to -oil ratio:
0.003254
m3/titer
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
0
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
El
Yes
0
No
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
,COLORADO
2 ,see.,
Permit Number:
AIRS ID Number: 123 / A0EA /
(Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Condensate Throughput:
Actual Annual Amount
(bbUyear)
216,017
Requested Annual Permit Limits
(bb(/year)
259,220
From what year is the actual annual amount?
Projected
Average API gravity of sales oil: 61.4 degrees
❑ Internal floating roof
Tank design: El Fixed roof
RVP of sales oil: 11.7
0 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
12
6,456
1/2019
3/2020
Welts Serviced by this Storage Tank or Tank Battery6 (E&P Sites On
y)
API Number
Name of Welt
Newly Reported Well
05
- 123
- 46886
Lory 1N
GI
05
- 123
- 46890
Lory 2N
Fl
05
- 123
- 46897
Lory 3N
12
05
- 123
- 46879
Lory 4N
IS
05
- 123
- 46884
Lory 5N
51
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)
40.26264 / -104.6668
❑Q Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack
ID No.
Discharge Height Above
Ground Level (Feet)
Temp.
(SF)
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)
o Circular
❑ Square/ rectangle
❑ Other (describe):
0 Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
3 L COLORADO
irit..ea,mu
Permit Number:
AIRS ID Number: 123 / A0EA /
[Leave blank unless APCD has already assigned a permit # and AIRS ID)
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPS
Rating: MMBtu/hr
Type: Enclosed Combustors
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Make/Model:
95
98
7 x Cimarron 48" & 1 x Cimarron 60'
Minimum Temperature: Waste Gas Heat Content: 2,460.49 Btu/scf
Constant Pilot Light: ID Yes ❑ No Pilot Burner Rating: MMBtu/hr
O Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 31.9 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
COLORADO
4� j>.
Permit Number:
AIRS ID Number: 123 I A0EA /
[Leave blank unless APCD has already assigned a permit 4 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 Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
V0C
Enclosed Combustors
100%
95%
NOx
CO
HAPs
Enclosed Combustors
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:
Pollutant
Emission Factor7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
tons/ear
( Y )
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
1.6664
lb/bbl
ProMax
179.99
9.00
215.99
10.80
NOx
0.1380
ib/MMBtu
TCEQ
N/A
0.90
NIA
1.08
CO
0.2755
lb/MMBtu
TCEQ
N/A
1.93
N/A
2.27
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 APEN5, including APEN updates.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non -Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non -criteria Yes
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor7
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP 42,
Mfg., etc.)
Uncontrolled
Emissions
(lbs/year)
Controlled
Emissions8
(lbs/year)
Benzene
71432
0.0048
lb/bbl
ProMax
1.037.63
51.88
Toluene
108883
0.0067
lb/lobl
ProMax
1.457.87
72.89
Ethylbenzene
100414
4.79E-05
lb/bbl
ProMax
10.36 (DM)
0.52 (DM)
Xylene
1330207
0.0025
lb/bbl
ProMax
548.35
27.42
n -Hexane
110543
0.0457
lb/bbl
ProMax
9,864.60
493.23
2,2,4-Trimethylpentane
540841
1.65E-05
lb/bbl
ProMax
3.56 (DM)
0.18 (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 wilt be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 5 I
COLORADO
I sm,vffis.o,m"nss
Permit Number:
y_. bang
AIRS ID Number: 1 23 / AOEA
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.
Si' . ure of Legally Authorized Person (not a vendor or consultant)
J ck Starr
G
(2.-e1-6
ate
Senior Air Quality Representative
Name (print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
El 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-B1
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
]P
COLORADO
• 6 I �.m
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
PDC Energy, Inc.
Source Name:
Lory 33 Sec HZ
Emissions Source AIRS ID2:
N/A / i2 I4EAEA /coZ.
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 46877
Lory 6N
i4
05 - 123 - 46876
Lory 7N
►,,
05 -123 - 46854
Lory 8N
►1
05-123-46838
Lory9N
►/
05 - 123 - 46855
Lory 10N
.1
05 - 123 - 46851
Lory 11N
2
05 - 123 - 46860
Lory 12N
►1
- —
❑
- -
❑
- -
❑
- -
❑
- -
■
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- _
O
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
Hydrocarbon Liquid Loading APEN
Form APCD-208
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 wilt 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:
2 JE, 7
AIRS ID Number: 123 / AOEA / 6O3
,. eavt btank .=n s, APED has _- h3k.ity assi?hies, pfir
Section 1 - Administrative Information
Company Name': pDC Energy, Inc.
Site Name: Lory 33 Sec HZ
Site Location: SWSE Sec 33 T4N R65W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person: Jack Starr
Phone Number: (303) 860-5800
E -Mail Address2: ,Jack.Starr@pdce.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes wilt require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-2O8 aria -o Liquid Loading APEF-4 R . is.on 17 <:0
-'COLORADO
nnp.mnm,m Public
IbMb En.Lonmme
Permit Number: AIRS ID Number:
123 /AOEA/
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly -reported emission source
El Request coverage under construction permit
0 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 0 Change company name3
O 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 -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info ft 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.
Section 3 - General Information
General description of equipment and purpose: Loading of condensate from storage tanks to tank trucks
Company equipment Identification No. (optional):
For existing sources, operation began on:
LOAD -1
3/4/2020
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
El
■
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
U
O
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
49
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
El
■
Does this source splash fill less than 6,750 bbl of condensate per year?
Yes
No
p
U
Does this source submerge fill less than 16,308 bbl of condensate per year?
Yes
No
■
GI
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 12/2019
2I
Depmrtramt Rift
COLORADO
*WO ie
❑ Upward
O Horizontal
Permit Number: AIRS ID Number:
123 /AOEA/
Section 4 - Process Equipment Information
Product Loaded: ❑✓ Condensate 0 Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
259,220
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this faci ity into: Tank Trucks
(e.g. "rail tank cars" or "tank trucks")
216,017
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 Loaded5:
bbl/year
Actual Volume Loaded:
bbl/year
Product Density:
tb/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)
40.26264 / -104.6668
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)
O Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
o Circular
O Square/rectangle
❑ Other (describe):
Interior stack diameter (inches):
Interior stack width (inches):
O Upward with obstructing raincap
Interior stack depth (inches):
i=o.r-" APCD 208 - d oc< r' o a=c:u d Lotto
COLONADO
3 y n.a. �..,nuauc
Permit Number:
AIRS ID Number:
123 /AOEA/
Section 6 - Control Device Information
0 Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
O Loading occurs using a vapor balance system:
Requested Control Efficiency: %
O Combustion
Device:
Used for control of: VOC and HAPS
Rating:
MMBtu/hr
hr
Type: Enclosed Combustor Make/Model:
1 x Cimarron 60"
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98 %
Minimum Temperature: F Waste Gas Heat Content:
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating:
2,460.49 Btu/scf
MMBtu / hr
O 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? ❑✓ Yes 0 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:
0 Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
✓❑ Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
0 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:
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
SOX
NO„
0.1380
Ib/MMBtu
TCEQ
N/A
0.13 (DM)
N/A
0.15 (DM)
CO
0 2755
Ib/MMBtu
TCEQ
N/A
027 (DM)
N/A
0 31 (DM)
VOC
0.2360
lb/bbl
State Approved
25.49
1 27
30.59
1.53
5 Requested values wilt become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APEN5, 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.
F _.r,m APtC'D,.;08 Hydrocarbon Lr quid Lcndli. c APEAPF:r4 12.,2019
Dembneatatlalic
COLORADO
Permit Number:
AIRS ID Number:
!L'... bank Jt AI�1 s already a', :gg1 e
123 /AOEA/
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?
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
(lbs/year)
Controlled
Emissions6
(lbs/year)
Benzene
71432
0.0004
Ib/bbl
State Approved
89 86 (DM)
4 49 (DM)
Toluene
108883
Ethylbenzene
100414
Xylene
1330207
n -Hexane
110543
00036
lb/bbl
State Approved
779.82
38.99
2,2,4-Trimethylpentane
540841
Other:
El Yes ❑ No
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.
Sign. ut- of Legally Authorize Person (not a vendor or consultant)
Jac
Starr
('fat
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
m APCD-208 y rccarbon Liquid Loading APEN R visi,,.n 12/2019
51
COLORADO
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