HomeMy WebLinkAbout20202058.tiff aW .M., COLORADO
'1 Y,is Department of Public
`oP"E Health 8 Environment
RECEIVED
Weld County - Clerk to the Board
1150 0 St MAY 1 1 2020
PO Box 758
Greeley, CO 80632 WELD COUNTY
COMMISSIONERS
May 7, 2020
Dear Sir or Madam:
On May 8, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC
Energy, Inc. - High Plains 25 Sec HZ; LaSalle 25 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 & Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
of Cd
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I.Tf r `q'
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director k,,, i„;-,j.
PubI:C Re ietJ cc:PLCTP) NL(ibO,Pw(S►^/ER/GH/cl), 2020-2058
07/2 0/2o oG�nj
O7/r3/2.O
CM�M4 Mil, Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: PDC Energy, Inc. - High Plains 25 Sec HZ; LaSalle 25 Sec HZ - Weld County
Notice Period Begins: May 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: High Plains 25 Sec HZ; LaSalle 25 Sec HZ
Oil and gas well production facility
NWNW Sec 25, T5N, R65W
Weld County
The proposed project or activity is as follows: Applicant proposes new synthetic minor limits at an existing
facility. Applicant proposes to utilize a vapor recovery unit to a portion of the vapors emitted from
condensate storage tanks.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0937 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd®state.co.us
• Send comments to our mailing address:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
T (COLORADO
Department of Public
1 I Health Et Environment
RECEIVED
CDPHE Condensate Storage Tank(s) APEN°CT 18 ?019
'�` �t3► Form APCD-205 Apcl'
stativnar„
CO Air Pollutant Emission Notice (APEN) and Sources
Application for Construction Permit
Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates.An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re-submittal.
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 at:www.cotorado.govlpacific/cdphetair-permits.
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: I cjhAj . n CI 31 AIRS ID Number: 123 '9CE6/014
[Leave blank unless APCD has already assigned a permit r`and AIRS ID)
Section 1 -Administrative Information
Company Name: PDC Energy, Inc.
Site Name: High Plains 25 Sec HZ; LaSalle 25 Sec HZ
Site Location
Site Location:
NWNW Sec 25 T5N R65W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code(
1775 Sherman Street, Suite 3000
Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address2: Jack.Starr@pdce.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
420956
Cotoao
Form APCD-2O5 Condensate Storage Tank(s)APEN- Revision 7/2018 1 I �� „��,° F.RA M.
Permit Number: AIRS ID Number: 123 I 9CE6/014
[Leave blank unless APCD has already assigned a permit r and AIRS ID)
Section 2- Requested Action
❑✓ NEW permit OR newly-reported emission source
0 Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 O GP08 •
If General Permit coverage is requested,the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment O Change company name3
❑ Change permit limit O Transfer of ownership{ O Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT AcTtofts-
❑ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emft(PTE)
Additional Info&Notes: Emissions calculated using previously approved site specific emission factors;Actual throughput and emissions are based
on a rolling twelve(12)month total due to a fug calendar year not yet being available:Additional emissions control from a tank VRU system is being claimed
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK 1 (2)
For existing sources,operation began on: 07/07/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s)located at: 0 Exploration a Production(E&P)site O Midstream or Downstream(non EEtP)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No
Are Flash Emissions anticipated from these storage tanks? 0 Yes O No
Is the actual annual average hydrocarbon liquid throughput≥500 bbl/day? 0 Yes O No
If"yes",identify the stock tank gas-to-oil ratio: 0.001766 m3/titer
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC)
✓ Yes O No
805 series rules?If so,submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual
✓ YesNo
emissions≥6 ton/yr(per storage tank)? O
Form APCD-205 Condensate Storage Tank(s)
APEN • Revision 7/2018 2 I AV COLORADO
Permit Number: AIRS ID Number: 123 /9CE6/014
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 4- Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bb(/year) (bb(/year)
Condensate Throughput: 906,551 1,087,861
From what year is the actual annual amount? Projected Requested Annual Limit during VRU downtime:
Average API gravity of sates oil: 50.7 degrees 707,110 bbl/yearRVP ofEsat�s oiEmi l�)4-22-2020
Tank design: 0 Fixed roof O Internal floating roof O External floating roof
Storage II of Liquid Manifold Storage Total Volume of Installation a of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Vessel In Production
(bbl) Storage Tank(month/year) (month/year)
TK-1 (2) 18 9,684 10/2017 7/2018
Wells Serviced by this Storage Tank or Tank Battery6(EBP Sites Only)
API Number Name of Well Newly Reported Well
05 -123 -44975 High Plains 25A-221 O
05 -123 -44974 High Plains 25A-241 O
05 •123 -44978 High Plains 25A-321 O
05 -123 -44976 High Plains 25A-341 O
05 -123 •44971 High Plains 25A-401ST O
5 Requested values will become permit limitations.Requested limit(s)should consider future growth.
6 The ESP 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 -Stack Information
Geographical Coordinates
(Latftude/Longitade or UTM)
40.374395/-104.620362
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(feet) (°F) (ACFM) (ft/sec)
N/A
Indicate the direction of the stack outlet: (check one)
o Upward O Downward O Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
COLORADO
Form APCD-2O5 Condensate Storage Tanks)APEN - Revision 7/2018 3 I `^0`,1_°.!..
Permit Number: MRS ID Number: 123 I 9CE6/014
[Leave blank unless APCD has already assigned a permit«and AIRS ID]
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.
Pollutants Controlled: VOC&HAPs
Vapor Size: Make/Model: EcoVapor Compressor
0 Recovery
Unit(VRU): Requested Control Efficiency: 100
VRU Downtime or Bypassed(emissions vented): 65
Pollutants Controlled: VOC&HAPs
Rating: MMBtu/hr
Type: Endosed Combustor Make/Model:9 x Cimarron 48"&1 x Cimarron 60"
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,240 Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7-Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 26.4 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
Form APCD-2O5 Condensate Storage Tank(s)APEN Revision 7/2018 4 I eV
Permit Number: AIRS ID Number: 123 /9CE6/014
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8- Emissions Inventory Information
Attach alt emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%►eduction in emissions)
VOC Enclosed Combustor and Tank VRU d8665rr 96.15%
NOx
CO
HAPs Enclosed Combustor and Tank VRU 96.75%
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factory Actual Annual Emissions Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions
Basis µfg,etc) (Tons/year) (Tons/year) (Tans/yam) (Tons/year)
VOC 0.7034 lb/bbl ProMax 318.84 10.6410.36 382.61 12.7712.43
NOx 0.1380 Ib/MMBtu TCEQ N/A 1.48 1.21 N/A 1.78 1.51
CO 0.2755 Ib/MMBtu TCEQ N/A 2.96 2.41 N/A 3.55 3.01 Per email
4/22/2020
Non-Criteria Reportable Pollutant Emissions Inventory -B.E.
Chemical Emission Factor? Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(Cu) Uncontrolled Units (AP-42, Emissions Emissions
Number Basis Mfg.etc) (Pounds/year) (Pounds/year)
Benzene 71432 0.0019 lb/bbl ProMax 1,721.70 57.46 56
Toluene 108883 0.0031 lb/bbl ProMax 2,786.63 93.00 91
Ethylbenzene 100414 0.0001 lb/bbl ProMax 89.28(DM) 2.98(DM) 3
Xylene 1330207 0.0013 lb/bbl ProMax 1,157.25 38.62- 38
n-Hexane 110543 0.0188 lb/bbl ProMax 17.038.01 568.64 554
2,2,4- 540841 0.0001 lb/bbl ProMax 71.45 (DM) 2.38 (DM)
Trimethylpentane
5 Requested values wilt become permit limitations.Requested limit(s)should consider future growth.
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 emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave
blank.
COLORADO
Form APCD-2O5 Condensate Storage Tank(s)APEN - Revision 7/2018 5 I �� "°""'"`"" '
Permit Number: AIRS ID Number: 123 /9CE6 i 014
[Leave blank unless APCP has already assigned a permit 4'and AIRS ID]
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 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.
(0//4/2"6/9
Sign u e of Legally Authorized Person(not a vendor or consultant) I Date
Jack Starr Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
(]i Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration
of the five-year term,or when a reportable change is made(significant emissions increase,increase production,
new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, ILC.for revised APEN requirements.
Send this form along with$191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable,to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver,CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.calorado.gov/cdphe/apcd
IRV COLORADO
Form APCD-205 Condensate Storage Tank(s)APEN- Revision 7/2018 6 ( kW. " `
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: PDC Energy,Inc.
Source Name: High Plains 25 Sec HZ;LaSalle 25 Sec HZ
Emissions Source AIRS ID2: 123/9CE6/014
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-44977 High Plains 25F-221 0
05-123-44970 High Plains 25F-301 0
05-123-44973 High Plains 25N-241 0
05-123-44972 High Plains 25N-301 0
- - 0
0
- ❑
0
0
0
- - ❑
- - 0
O
0
- - 0
0
0
0
0
0
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter
N/A
Form APCD-212 TK-1 (2)APEN Addendum
4/27/2020 State.co.us Executive Branch Mail-RE:[EXTERNAL]:PDC Energy-High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks(Point 014)
STATE OF Eades-CDPHE,Bradley<bradley.eades@state.co.us>
I I COLORADO
RE: [EXTERNAL] :PDC Energy - High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks (Point 014)
Jack Starr<Jack.Starr@pdce.com> Wed,Apr 22,2020 at 4:54 PM
To:"Eades-CDPHE,Bradley"<bradley.eades@state.co.us>
Brad,
You're not missing something.My calcs were adding an additional 20%to CO emissions for some reason.I apologize for that.
Please see attached the corrected calcs and facility-wide emissions inventory.
Jack Starr
Senior Air Quality Representative-Wattenberg
(303)318-61611 Direct
(720)501-86111 Cell
Jack.Starr@pdce.com
to ORGY
PDC Energy[ 1775 Sherman Street Ste 30001 Denver,CO 80203 I NASDAQ:PDCE
This email,including attachments,may include confidential and/or proprietary information,and may be used only by the person or entity to which it is addressed. Please do not read,copy or
disseminate this communication unless you are the intended addressee.If you received this communication in error,please permanently delete and call(800)624-3821 immediately and ask to speak to
the sender of this communication.Also,please notify immediately via e-mail that you have received this message in error.
SIIA Please consider the environment before printing this e-mail.Thank You.
From:Eades-CDPHE,Bradley[mailto:bradley.eades@state.co.us]
Sent:Wednesday,April 22,2020 11:25 AM
To:Jack Starr<Jack.Starr@pdce.com>
Subject:Re:[EXTERNAL]:PDC Energy-High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks(Point 014)
Hi Jack,
I am doing well,all things considered. I hope the same for you.
Your revised calcs look good to me.The approach you've used here should arrive at approximately the same result and is probably more accurate in
our case since I had only originally included flash while your approach should capture flash and W&B gas.So I'm good to go with yours.However,I am
getting a different result for CO:
0.2755 lb/MMBtu x 21,852 MMBtu/yr/2000 lb/ton=3.0 tpy CO.Your calc indicates 3.6 tpy.Am I still missing something?
https://mail.google.com/mail/u/0?ik=32956e8fae&view=pt&search=all&permmsgid=msg-f%3A1664715132033608074&dsgt=l&simpl=msg-f%3A1664... 1/4
4/27/2020 State.co.us Executive Branch Mail-RE:[EXTERNAL]:PDC Energy-High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks(Point 014)
On Mon,Apr 20,2020 at 12:11 PM Jack Starr<Jack.Starr@pdce.com>wrote:
Hi Brad,
I hope you're doing well and staying healthy during all of this craziness!
Please see my responses below in blue.
If you have any further questions or would like to discuss this application at all,please do not hesitate to let me know.
Thanks,
Jack Starr
Senior Air Quality Representative-Wattenberg
I (303)318-61611 Direct
(720)501-86111 Cell
Jack.Starr@pdce.com6Elicitor
PDC Energy 11775 Sherman Street Ste 3000 I Denver,CO 80203 I NASDAQ:PDCE
This email,including attachments,may include confidential and/or proprietary information,and may be used only by the person or entity to which it is addressed. Please do not read,copy or
disseminate this communication unless you are the intended addressee.If you received this communication in error,please permanently delete and call(800)624-3821 immediately and ask to
speak to the sender of this communication.Also,please notify immediately via e-mail that you have received this message in error.
Please consider the environment before printing this e-mail.Thank You.
From:Eades-CDPHE,Bradley[mailto:bradley.eades@state.co.us]
Sent:Wednesday,April 15,2020 3:06 PM
To:Jack Starr<Jack.Starr@pdce.com>
Subject:[EXTERNAL]:PDC Energy-High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks(Point 014)
Hi Jack,
I am processing the construction permit application for storage tanks associated with the High Plains wells(Point 014)at the High Plains25HZ-
LaSalle25HZ facility.These tanks were previously covered under GP01,and PDC intends to convert permit coverage to an individual permit with this
issuance.
https://mail.google.com/mail/u/0?ik=32956e8fae&view=pt&search=all&permmsgid=msg-f%3A1664715132033608074&dsgt=1&simpl=msg-f%3A1664... 2/4
4/27/2020 State.co.us Executive Branch Mail-RE:[EXTERNAL]:PDC Energy-High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks(Point 014)
Please respond to the following questions regarding this application.I am taking over this project from the engineer previously working on this
project(Timothy Sharp,who has since resigned his position with the Division),so I apologize for any questions that may be repeated:
1.The APEN for these tanks indicates 18 vessels connected via liquid manifold with a total capacity of 9,684 bbl.Is it safe to assume the storage
capacity of each tank is roughly 538 bbl?That is correct.Each tank's capacity is 538 bbl.
2.I am calculating a higher control efficiency(96.75%)than what is reflected on the APEN(96.66%)based on 65%of emissions to the ECD and
35%recycled. I intend to include 2 process limits in the permit,one for total condensate throughput and another for condensate throughput while
emissions are routed to the ECD.I've attached my calculation spreadsheet.Can you please review and let me know if you agree with the controlled
emissions/control efficiency.If so,please provide an APEN addendum to reflect the corrected calculations.The GOR(scf/bbl)is based on the
ProMax simulation submitted October 2018 with the original GP01 application.I agree with your calculation spreadsheet.It looks like the initially
submitted calcs/APEN were only claiming a 95%capture efficiency in addition to the 35%runtime for the tank VRU.That caused the total control
efficiency to be 96.66%.I've attached an updated calc page and facility-wide emissions inventory that reflects the higher total control efficiency and
corresponding emissions.
The updated calc page still shows a slight discrepancy with your calculation spreadsheet for NOx and CO,however.PDC has historically calculated
flash gas volume with the equation shown below:
Flask Gal 3,„
Eineentivnad VOC(_)s �x )s1 tan NWl3 i�r wat Il sBoat Content�rc ( Btulei X163
With the outputs from the October 2018 ProMax run the equation is:
Thu&Gae 7d9d$tae
Yr
61 0Q0 1 37991 ac Gal 1 Btu 1 $ iv
jir ton x ?tS6 i15 i� t6 snroT 6d7�6 roc)x Boat Conte itlo$i9c _�6
lb anal 21.1852==Btu
air
To maintain consistency,PDC would prefer to use the methodology above.However,I'm open to using just the GOR,heat content,and tank
throughput if you would rather do that.If so,I can update the calc page accordingly.
If you have any questions,let me know.
Thanks,
Brad
Bradley Eades
Oil Et Gas Permitting Engineer
Oil Et Gas Program
Colorado Department of Public Health Et Environment
P 303.692.3142 I F 303.782.0278
4300 Cherry Creek Drive South,Denver,CO 80246-1530
https://mail.google.com/mail/u/0?ik=32956e8fae&view=pt&search=all&permmsgid=msg-f%391664715132033608074&dsgt=1&simpl=msg-f%3A1664... 3/4
4/27/2020 State.co.us Executive Branch Mail-RE:[EXTERNAL]:PDC Energy-High Plains 25HZ;LaSalle 25HZ Well Pad Storage Tanks(Point 014)
bradley.eades®state.co.us I www.colorado.gov/apcd
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
Bradley Eades
Oil£x Gas Permitting Engineer
Oil Et Gas Program
I 1
Colorado Department of Public Health Et Environment
P 303.692.3142 I F 303.782.0278
4300 Cherry Creek Drive South,Denver,CO 80246-1530
bradley.eades@state.co.us I www.colorado.gov/apcd
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
2 attachments
fly Updated TK-1(2)Calcs_High Plains LaSalle.pdf
39K
APCD Form-102_High Plains LaSalle.pdf
28K
https://mail.google.com/mail/u/0?ik=32956e8fae&view=pt&search=all&permmsgid=msg-f%3A1664715132033608074&dsgt=l&simpl=msg-f%3A1664... 4/4
Company Name:PDC Energy,Inc.
Facility Name:High Plains 25 Sec HZ;LaSalle 25 Sec HZ
Condensate Storage Tank Emissions Calculations-TK-1(2)High Plains Wells
Actual Production(bbl/yr): 906,551 Actual Production While Controls Operational(bbl/yr): 906,551
Requested Production(bbl/yr): 1,087,861 Requested Production While Controls Operational(bbl/yr): 1,087,861
Flash gas(MMBtutyr): 21,852.08 Tank VRU Downtime: 65%
Pollutant Emission Factor EF Units Control Actual Uncontrolled Actual Controlled Requested Requested
Efficiency Uncontrolled - Controlled
VOC(TPY) 0.7034 lblbbl. 96.75% 311.84 10.36 382.61 12.43
NOx(TPY) 0.1380 lb/MMBtu 96.75% WA 1.21 N/A 1.51
CO(TPY) 0.2755 lb/MMBtu 96.75% WA 2.41 N/A 3.01
Benzene(lb/yr) 0.0019 Iblbb 96.75% 1721.70 55.98 2066.04 67.15
Toluene(lb/yr) 0.0031 lb/bb 96.75% 2786.63 90.57 3343.96 108.68
Ethylbenzene(lb/yr) 0.0001 Iblbb 96.75% 89.28 2.90 107.14 3.48
Xylene(lb/yr1 0.0013 Ib/hb 96.75% 1157.25 37.61 1388.70 45.13
n-Hexane(lb/yr) 0.0188 lb/bb 96.75% 17038.01 553.74 20445.61 664.48
2,2,4-TMP(lb/yr) 0.0001 lb/bb 96.75% 7t45 2.32 85.73 2.79
Production forecasts are based on the first thirty(30)days of production for new wells.The average daily production rate from those first thirty(30)days is then multiplied by
365 to achieve an annualized production value.This annualized production value then has the default decline factor of 60%'applied to forecast the first 12 months of production
from those new wells.
Production for existing wells is forecasted using a daily average that is annualized based on the most current data available.
Production while controls operational represents a portion of this facilitys production where the tank emissions were uncontrolled.
1-Decline Facterof 60%-PS Memo 0501'Oda Gas Condensate Tank Batteries Regulelory DefiMnns and Pernari,g Guidance'
NOx and CO emission factors were taken from Table 4 of the Texas Natural Resource Conservation Commission's(TNRCC)"Air Permit Technical Guidance for Chemical Sources-
Flares and Vapor Oxidizers"document(shown as TCEO'on any associated APENs).The waste gas stream is assumed to be high-Btu(5 1,000 Btu/scf).
Site Specific Emission Factorshave been used to calculate emissions.
Example Calculations: l / /
Uncontrolled Emissions(11-2-)==Annual Uncontrolled Throughput)bell Emission Factor{))
yr `yr J 111 bbl
Ira:*VRU Control Efficiency.=(1—VRU Downtime%)•(VRU Capture/Control Efficiency)
IContm el Ef fictency=1—((1—VRO Control Efficiency)'(1—ECD Control Effinmcf•ji
Controlled Emissions yr J=Annual Controlled Throughput( ()-Emission Factarl bbl){I Control Efficiency)
( +Annual Uncontrolled Throughputt bell Emission Factor'`-1
/I Yr J
VOC Emissions)10 I=Emissions)M l r l ion )
( l yr `yr)12,00016
Flash Gail M,NB1u)=
l yr 1
Unconmolbd VOC1'1.(2.000Ib)r 1 l.(379.41SCF Gas)( I ).Hem Conten�B?)(IM.MBtu)
Jrr ` ton// Gas MW ` lb
/—mol 1 I VOCYa SCF l 10"Btu
NOx&COl7°o)=Emission Factors lb )•Flash Gas{MMBm)( Mon)
`yr 111 MMBtu l yr I`20001b
NOTE:Flash gas heat content,molecular weight and VOC fraction are based on ProMax 4.0 emission simulation.
Colorado Department of Public Health and Environment
Form APCD-102 Air Pollution Control Division AIL rigi402.5W-t7'.
Facility Wide Emissions Inventory Form
Ver.April,2013 t
Company Name:PCC Energy Inc.
Source Name:Hgh Mains 2S Scc ISE aSalle25 Sec HZ ide
Source AILS ID:123/9CE6
ancommea Pam.,to mammal commea Poim,te ema,PM3 •
U ..
airmT da Rr„ ria(1'x>N v.{w r)
03013memnunlPdon a_ a r111 .4ero ozo m ea Mom _ _ «0 uzoZO 271 04100 11.1.040
111
x,11 taco 000 0 00. OM oo Mai 0.00 189.03
n
inamomi 1QI
crnNA6 c 11 _ _
63 000 0.00 0 00 196.35 0 00 000
camillorll7306o0 045 0.05 0.05 ORO 17.92 0.65 17.92 718, 29 06 27.40 1646 0.00 000 000 000 000 0.00 0.05 0.05 0.05 ORO 133 0.93 1116 713, 29.06 27, 16.45 000 0 00 0.00 0 00 ORO OW.
123.ale,2 ze01117 217,31. 11.114 0 04 ORO 1137 1.91 14, 159.96 11.63 2039 11, 000 000 000 000 Oa 000 OM. 004 0, 0110 182 1.82 197 158.96 21 53 2039 12, IMO OM 11191 DUO .nm 0 110
NM sources sn0wul= 0.13 033 0.13 0.01 41.49 519.19 46.90 1,09641 7.11 9438 2,619.95 324336 10].14 1389.70 24,936.00 0.00 BSA 0.13 0.13 0.13 0.01 654 3639 1240 1,086.01 99.11 2458 11_14 M. 3.48 4633 922.61 0.00 _.99
♦ um C<e p u.m 1435
.10o 4.39 247 000 0.00 000 0oo o.00 o.00
Axrn Only..I. OM 0.04 Oa 0.00 1241 119 29.61 18951 93.93 _4.19 1439 0.00 0.00 0.00 mio 0.00 0.00 0.04 0.04 0.04 0.00 1.95 0.65 26.04 18933 15.99 NM 1139 ono Ono Roo 0.00 0.00 0.00
♦ 6 +mwurwr c - i°40
oo oro 77.4 er r1
Mama wau'Tanim 11-2 p1 me 0.00 O.Oo 000 0.00 OM 0.00 000 0.00 000 117 9.01 0_6 3_0 9_6 0.00 0.w ON 0.00 000 0.0.3 ON 045 Ono ,M U.W OM .9.13 9.03 U_o 3._0 9.2o 0.00 0.00
4ukm0comewmw- oM 034 034 0.03 J 1.04 3.71 OM 0.00 .0m 4338 24.96 13.73 18.99 9693 0.00 0.00 021 034 0.34 0.03 4.41 1.04 3.91 0.00 Ono 0.00 4538 18.19 96.93 0.00 0.00
0,33 1 031 031 1 0.04 70.77 1 533,1 90, 123334 I tw.mm1 98391 x691.313269.921 1323911,403491 15,03341 10.00 1 86.73 10.511 0-J1 1 031 10.04 111.91 1 39.28 1 4143 1.27524 1,30 1.37 110111[133, 14.21'1 03.92 1419,1 040 1I 1.99 •
00<omr0mdnd?s mno7n-) 0.64 I o.os I am I 900 1 1.60 10.00 I 0.90 I 930 i 0.00 I Oa I sommormsom-1 0.64 1 0.05 1 005 10.10 0.08 1 0.01 1 0.,1 031 1 0.00 I 0.00
umm�lwi102r0.unn,r.rrP,y-1 19..0 I 4anlwnid Tout.nn,P,rrnv1-I 1.46
Footnotes:
1.This farm she he completed to iuclede both 8391.08 somecs and all proposed newer modifications to misting emissions somas
2.VA]emissions oour%is new then enter"proposed"under Me Permit No.and AIRS ID data°dorms
3.HAP Mbrevimions include:
HZ-Hmzeue 204-TIVI 4-Tdmethylpmtme
Sol=Toluene Acemt-AcetalA0010tdehyde
£H-£Ihydbenzene Aer0=.Aerolin
Xyl=Xylene n-Hex=m-Howe
HCHO=Formaldehyde Meth Methanol
4.APINP empNusiim5eaut Sources Mould 1m imluded Mono wmauted.
PCC Energy,Inc. 4122/2020 Page 1 of 1
- -'M- COLORADO
Air Pollution Control Division
• Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0937 Issuance: 1
Date issued:
Issued to: PDC Energy, Inc.
Facility Name: High Plains 25 Sec HZ; LaSalle 25 SEC HZ
Plant AIRS ID: 123/9CE6
Physical Location: NWNW SEC 25 T5N R65W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
Emissions from the
storage vessels are
routed to a sales
pipeline through the
use of a vapor
Eighteen (18) 538 barrel fixed roof recovery unit (VRU).
TK-1 (2) 014 condensate storage vessels connected via During VRU
liquid manifold. downtime, emissions
are routed to
enclosed
combustor(s). The
VRU has a maximum
of 65% annual
downtime.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
Page 1of10
COLORADO
.ti,Y= Air Pollution Control Division
CDFHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
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 AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO,t VOC CO Type
TK-1 (2) 014 --- 1.6 12.5 3.1 Point
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
6. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
Page 2 of 10
C -;�M,.,- COLORADO
Air Pollution Control Division
CDPHE
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
Emissions from the storage vessels are
routed to a sales pipeline through the use
TK-1 (2) 014 of a vapor recovery unit (VRU). During VRU VOC and HAP
downtime, emissions are routed to enclosed
combustor(s). The VRU has a maximum of
65% annual downtime.
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS_
Equipment Process Parameter Annual Limit
ID Point
Total condensate throughput 1,087,861 barrels
TK-1 (2) 014 Condensate throughput during VRU
downtime. 707,110 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
9. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the condensate storage vessels are routed to the
enclosed combustor(s). The total hours of VRU downtime, total condensate throughput volume
and total condensate throughput volume during VRU downtime shalt be recorded on a monthly
basis. The owner or operator must use monthly VRU downtime records, monthly condensate
throughput volume records, and the calculation methods established in the Notes to Permit
Holder to demonstrate compliance with the process and emission limits specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
Page 3 of 10
M- COLORADO
— Air Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of 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)
13. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions(State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.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 I II.B.2.d.
14. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
15. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing 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
Page 4 of 10
'N.,.,. COLORADO
Air Pollution Control Division Cn
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
17. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (O&tM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&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
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. 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 (N0r) in ozone
nonattainment areas emitting less than 100 tons of V0C or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
21. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
Page 5 of 10
.H..^1M- 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
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will',provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
Page 6 of 10
�M,._a 1,.... COLORADO
_ _ Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Bradley Eades
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc. for a point previously
registered under a general permit
Page 7 of 10
:,M�M` COLORADO
• Air Pollution Control Division
CDPHE
Department of Public Health 8 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-regs
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS Uncontrolled Controlled
Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr)
Benzene 71432 2;,066 67
Toluene 108883 3,344 109
Ethylbenzene 100414 107 3
014 Xylenes 1330207 1,389 45
n-Hexane 110543 20,446 664
2,2,4-
540841 86 3
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
Page 8 of 10
rv-. COLORADO
aAir Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Controlled
Emission Controlled
Uncontrolled Factors Emission
CAS # Pollutant Emission When Factors During Source
Factors Emissions are VRU Downtime
(lb/bbl) routed to the (lb/bbl)
VRU
- (lb/bbl)
NOx 3.1x10-3 --- 3.1x10.3 TNRCC
CO 6.1x10"3 --- 6.1x10"3
VOC 0.7034 0.00 0.0352
71432 Benzene 0.0019 0.00 3.5x10-5
108883 Toluene 0.0031 0.00 1.5x10-4 ProMax
1330207 Xylene 0.0013 0.00 6.4x10-5
110543 n-Hexane 0.0188 0.00 9.4x10-4
Note: : The controlled emissions factors for this point are based on a control efficiency of 100% when
emissions are routed to the VRU and a control efficiency of 95%when emissions are routed to the
enclosed combustor(s). The site specific emission factors for this source were developed using a
site specific pressurized liquid sample in conjunction with ProMax. Uncontrolled actual VOC and
HAP emissions are calculated by multiplying the emission factors in the table above by the total
condensate throughput. Controlled actual VOC and HAP emissions are calculated by multiplying
uncontrolled emissions by a 100%control efficiency,when emissions are routed to the VRU and a
95% control efficiency when emissions are routed to the enclosed combustor(s) (i.e. during VRU
downtime). The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission
factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted
to units of lb/bbl using a gas to oil ratio (GOR) of 9.914 scf/bbl and a heat content of 2,240
Btu/scf. Actual NOx and CO emissions are calculated by multiplying the emission factors in the
table above by the total condensate throughput during VRU downtime.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, HAP
PSD Synthetic Minor Source of: VOC
Page 9 of 10
rz., COLORADO
• 44wY'_ Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
NANSR Synthetic Minor Source of: VOC, NOx
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.Roy/
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
Review Engineer: Bradley Eades
Package $4: 420958
Received Date: 10/18/2019
Review Start Date: 11/4/2019 (T Sharp) 4/15/20 (B Eades)
Section 01 - Facility Information
Company Name: PDC ENERGY, INC. Quadrant Section Township Range
County AIRS ID: 123 NWNW 25 5N 65W
Plant AIRS ID: 9CE6
Facility Name: HIGH PLAINS 25 SEC HZ; LASALLE 25 SEC HZ
Physical
Address/Location : NWNW quadrant of Section 25, To n.nship SN, Range 65WW
County: Weld
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes, for what pollutant? ❑ Carbon Monoxije (CO) ❑ Particulate Matter (PM) El Ozone (NOx & VOC)
Section 02 - Emissions Units In Permit Application
Emissions Self Cert Engineering
AIRs Point P Emissions Source Type Equipment Name Permit # Issuance P Action
Control? Required? Remarks
Permit Initial
014 Condensate Tank TK-1 (2) Yes 19WE0937 1 Yes Issuance
Section 03 - Description of Project
Applicant is requesting an individual construction permit for source previously covered by GP01. Since GP01 carries a 39 tpy VOC limit, enforceable PTE is decreasing with
this permitting action.
This facility has two (2) production trains, each servicing a group of wells (High Plains wells and LaSalle wells). The facility is aggergated as a single source, however production
is tracked separately. This point reflects tanks servicing the High Plains wells. Point 001 storage tanks service the LaSalle wells. The emission factors used in this analysis are
from the ProMax simulation submitted Oct 5, 2018 (application for GP01).
Public notice is required for this permit since source became a Major Source with respect to NA NSR on January 27, 2020 (rede signation of the DMNFR to "Serious"
nonattainment"). With the limits contained herein, source will become synthetic minor.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) El ❑ O U ❑ ❑
Title V Operating Permits (OP) O ❑ ❑ a ❑ ❑ O Fl
Non-Attainment New Source Review (NANSR) ❑✓ Q
Is this stationary source a major source? No
If yes, explain what programs and which pollutants here SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ 0 0 0 ❑
Title V Operating Permits (OP) O ❑ ❑ ❑ El ❑ O O
Non-Attainment New Source Review (NANSR) ❑ ❑
Condensate Storage Tank(s) Emissions Inventory
Section 01 - Administrative Information
123 9CE6 014
Facility AIRs ID: County Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Eighteen (18) 538 bbl storage vessels connected via liquid manfold
Description:
Emission Control Device Emissions are recycled by vapor recovery unit (VRU) via close loop system. During VRU downtime, emissions are routed
Description: to enclosed combustors
Requested Overall VOC & HAP Control
Efficiency %: 96.75 %
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Total (process 01 + process 02)
Actual Condensate Throughput = 906,551 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 906,551 Barrels (bbl) per year
Requested Permit Limit Throughput = 1,087,861 Barrels (bbl) per year Requested Monthly Throughput = 92394 Barrels (bbl) per month
Potential to Emit (PTE)
Condensate Throughput = 1,087,861 Barrels (bbl) per year
% recycled 35%
% to flare 65%
Process 01 (emissions routed to VRU)
Actual Condensate Throughput = 317,293 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 317,293 Barrels (bbl) per year
Requested Permit Limit Throughput = 380,751 Barrels (bbl) per year Requested Monthly Throughput = 32338 Barrels (bbl) per month
Potential to Emit (PTE)
Condensate Throughput = 380,751 Barrels (bbl) per year
Requested Overall VOC & HAP Control
Efficiency %: 100 %
Process 02 (emissions routed to Enclosed Flare)
Actual Condensate Throughput = 589,258 Barrels (bbl) per year Actual Condensate Throughput While Emissions Controls Operating = 589,258 Barrels (bbl) per year
Requested Permit Limit Throughput = 707,110 Barrels (bbl) per year Requested Monthly Throughput = 60056 Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput 707,110 Barrels (bbl) per year
Requested Overall VOC & HAP Control
Efficiency %: 95 °,6
Secondary Emissions from Process 02 - Combustion Device(s)
Heat content of waste gas
= 224O Btu/scf
Volume of waste gas
emitted per BBL of liquids
produced = 13.796 scf/bbl
Actual heat content of waste gas routed to combustion device = 18,210 MMBTU per year
Requested heat content of waste gas routed to combustion device = 21,852 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 21,852 MMBTU per year
Section 04 - Emissions Factors & Methodologies
t5Wz ra ga"ws.94 %r.
Will this storage tank emit flash emissions? Yes
Process 01 (to VRU)
Emission Factors Condensate Tank
Uncontrolled Controlled
(lb/bbl) (lb/bbl) Emission Factor Source
Pollutant
(Condensate (Condensate
Throughput) Throughput)
VOC 0.7034 0.00 Site Specific E.F. (includes flash)
Benzene 0.0019 0.00
Toluene 0.0031 0.00
Ethylbenzene 0.0001 0.00
Xylene 0.0013 0.00
n-Hexane 0.0188 0.00
224 TMP 0.0001 0.00
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///.//� f/: / i 7"n/J7,5rf ) w %h hit Yrr, /A' rite / �%J ; j/1� /r.-/ k,41:
//./2 / / / f. / . v r %/:/GAT/////,r,,' / / // r r�� ,dry
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/ i/ -� / � : . "` 3 <� .rj �•Ci/l'7 �� 1 / rte. J/i/ � %�%J%�il/i //%
% r / � . /,,%//%�,�',%� r /iii i'. 1, / �p�.C:d:'p%.. , -, N �, .;_r//// •� . ////Y i�'.!i S' •r!ii!�i ri/ f � ;.
Wv, pie .:•i /G f r, : Or ..�Ay ' ' '' -Olin, `� ;�r �`�'i' x/ =at` 9 < ` 4°,
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Condensate Storage Tank(s) Emissions Inventory
Process 02 (to Enclosed Flare)
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 0.7034 0.0352 Site Specific ES (includes flash)
Benzene 0.0019 9.5E-05
Toluene 0.0031 1.5E-04
Ethylbenzene 0.0001 4.9E-06
Xylene 0.0013 6.4E-05 .
n-Hexane 0.0188 9.4E-04
224 TMP 0.0001 3.9r-06
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 0.0002 AP-42 Table 1.4-2 (PM10/PM.2.5)
PM2.5 0.0075 0.0002 AP-42 Table 1.4-2 (PM10/PM.2.5)
NOx 0.1380 _ 0.0043 ThRCC Flare Em ssions Guidance (NOx)
CO 0.2755 0.0085 TNRCC Flare Em ssions Guidance (CO)
Section 05 - Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month)
VOC 382.6 318.8 10.4 382.60 12.43 2112
PM10 0.1 0.1 0.1 0.1 0.1 _ 14
PM2.5 0.1 0.1 0.1 0.1 0.1 14
NOx 1.5 1.3 1.3 1.51 1.51 256
CO 3.0 2.5 2.5 3.01 3.01 511
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(lbs/year) (lbs/year) (lbs/year) (lbs/year) (lbs/year)
Benzene 2066 1722 56 2066 67
Toluene 3344 2787 91 3344 109
Ethylbenzene 107 89 3 107 3
Xylene 1389 1157 33 1389 45
n-Hexane 20446 17038 554 20446 664
224 TMP 86 71 2 86 3
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B Source requires a permit
Regulation 7, Part D,Section I.C, D, E, F Storage tank is subject to Regulati an 7, Part D, Section I.C-F
Regulation 7, Part D,Section I.G, C Storage Tank is not subject to Regulation 7, Section 1.6
Regulation 7, Part D,Section II.B, C.1, C.3 Storage tank is subject to Regulation 7, Part 0, Section II, 8, C.1 & C.3
Regulation 7, Part D,Section II.C.2 Storage tank is subject to Regulation 7, Part D, Section II.C.2
Regulation 7, Part D,Section II.C.4.a.(i) Storage Tank is not subject to Regulation 7, Part D, Section 1LC.4.a(i)
Regulation 7, Part D,Section II.C.4.a.(ii) Storage Tank is not subject to Regulation 7, Part D, Section I1.C.4.a(ii), b - f
Regulation 6, Part A, NSPS Subpart Kb Storage Tank is not subject to NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000 Storage tank is not subject to NSPS 0000.
NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a
•
Regulation 8, Part E, MACT Subpart HH Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions? No
If yes, are the uncontrolled actual or requested emissions estimated to be greater than or equal to 80 tons VOC per year? No
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions? Yes
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? This sample should be considered representative which gererally means site-specific and
collected within one year of the application received date. However, if the facility has not been modified (e.g., no
new wells brought on-line), then it may be appropriate to use an older site-specific sample. 111111
If no, the permit will contain an "Initial Compliance" testing requirement to develop 3 site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95% for a flare or combustion device? --
If yes, the permit will contain and initial compliance test condition to demonstrate tFe destruction efficiency of the combustion device based on inlet and outlet concentration sampling
Section 08 - Technical Analysis Notes
No wells have been added since previous approval of site-specific emission factors. As a result, they are being approved here.
Section 09 - Inventory SCC Coding and Emissions Factors
Uncontrolled
Emissions
AIRS Point SS SCC Code Pollutant Factor Control % Units
001 4-04-0631AttaikoOf Tank. Condensate, working+breathing+flashing losses PM10 0.01 0 Ib/1,000 gallons condensate throu,
PM2.5 0.01 0 lb/1,000 gallons condensate throu,
NOx 0.10 0 Ib/1,000 gallons condensate throui
VOC 16.7 97 Ib/1,000 gallons condensate throu,
CO 0.20 0 Ib/1,000 gallons condensate throu,
Benzene 0.05 97 lb/1,000 gallons condensate throu,
Toluene 0.07 97 Ib/1,000 gallons condensate throu,
Ethylbenzene 0.00 97 Ib/1,000 gallons condensate throu,
Xylene 0.03 97 Ib/1,000 gallons condensate throu,
n-Hexane 0.45 97 lb/1,000 gallons condensate throu,
224 TMP 0.00 97 Ib/1,000 gallons condensate throu,
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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
Source is in the Non-Attainment Area J
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Produced Water Tanks have no grandfathering provisions011
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part 8, Section 11.0.3)?
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this indivicual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)? Ye-: Source Requires an APEN. Go to
2. Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 (or additional guidance on grandfather applicability)? ti Go to next question
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.0.2)? Yes Source Requires a permit
Source requires a permit
Colorado Regulation 7, Part D, Section l.C-F &G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area (Regulation 7, Part D, Section I.A.1)? Yes Continue - You have indicated th
2. Is this storage tank located at oil and gas operations that collect, store, or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant (Regulation 7, Part D, Section I.A.1)? Yes Continue - You have indicated th
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section 1.6)? No Storage Tank is not subject to Re
4. Does this storage tank contain condensate? Yes
5. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids emissions (Regulation 7, part D, Section 1.6.2)? Yes
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D. Section I.D.3.a(ii))? Ye:
Storage tank is subject to Regulation 7. Part D, Section I.C-F
Part D, Section I.C.1 -General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Part D, Section I.C.2 - Emission Estimation Procedures
Part D, Section 1.D - Emissions Control Requirements
Part D, Section I.E - Monitoring
Part D, Section I.F - Recordkeeping and Reporting
Storage Tank is not subject to Regulation 7, Section LG
Part D, Section I.G.2 - Emissions Control Requirements
Part D, Section I.C.1.a and b - General Requirements for Air Pollution Control Equipment- Prevention of Leakage
Colorado Regulation 7, Part D. Section II
1. Is this storage tank located at a transmission/storage facility? No Continue - You have indicated th
2. Is this storage tank' located at an oil and gas exploration and production operation , well production facility?, natural gas compressor stations or natural gas processing plant`(Regulation 7, Part D, Section II.C)? Yes Go to the next question - You ha
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section II.A.20)? Yes Go to the next question
4. Are uncontrolled actual emissions of this storage tank equal to or greate- than 2 tons per year VOC (Regulation 7, Part D, Section II.C.1.c)? Yes Source is subject to parts of Regi
Storage tank is subject to Regulation 7, Part D. Section II, 8, Z.1 & C.3
Part D, Section II.B-General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D, 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, Par D, Section II.C.2.b)? No Source is subject to all provision!
Storage tank is subject to Regulation 7, Part D, Section ILC.2
Part D, Section II.C.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 at a 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 D, Section II.C.4.a.(i)? No Storage Tank is not subject to Re
Storage Tank is not subject to Regulation 7, Part D, Section I .C.4.a(i)
Is the controlled storage tank located at a well production facility, natural gas compressor station, or natural gas processing plant constructed on or after January 1, 2021 or located at a facility that was modified on or after January 1,
7. 2021, such that an additional controlled storage vessel is constructed to -eceive an anticipated increase in throughput of hydrocarbon liquids or produced water (Regulation 7, Part D, Section II.C.4.a.(ii)? No
Storage Tank is not subject to Regulation 7, Part D. Section 1;-C.4.a(Ii), b • f
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m3) (`472 BBLs) (40 CFR 60.110b(a))? Yes Go to the next question
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)? Yes Storage Tank is not subject NSPS
a. Does the vessel has a design capacity less than or equal to 1,589.874 m' (-10,000 BBL) used for petroleum' or condensate stored, processed, or treated prior to custody transfer? as defined in 60.111b?
3. Was this storage vessel constructed, reconstructed, or modified (see def nitions 40 CFR, 60.2) after July 23, 1984 (40 CFR 60.11ob(a))?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
S. Does the storage vessel store a "volatile organic liquid (VOL)"s as defined in 60.111b?
6. Does the storage vessel meet any one of the following additional exemptions:
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa (-29.7 psi) and without emissions to the atmosphere (60.110b(d)(2))?; or
b. The design capacity is greater than or equal to 151 m3 (`950 BBL) and stores a liquid with a maximum true vapor pressure' less than 3.5 kPa (60.11ob(b))?; or
c. The design capacity is greater than or equal to 75 M3 (472 BBL) but less than 151 m3 (-'950 BBL) and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.11ob(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 m' ('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 kPa?; or
b. The design capacity is greater than or equal to 75 M3 (-472 BBL) but less than 151 m' (^'950 BBL) and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa?
Storage Tank is not subject to NSPS Kb
40 CFR, Part 60, Subpart 0000/0000a, Standards of Performance for Crude Oil and Natural Gas Production,Transmission and Distribution
1. Is this storage vessel located at a facility in the onshore oil and natural gay production segment, natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue - You have indicated th
2. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) between August 23, 2011 and September 18, 2015? No Storage Tank is not subject NSPS
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after September 18, 2015? Ye: Go to the next question
4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year? No Storage Tank is not subject NSPS
5. Does this storage vessel meet the definition of "storage vessel"? per 60.5430/60.5430a? Yes Go to the next question
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart lill?
Storage Tank is not subject to NSPS 0000a
[Note: If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS 0000/0000a per
60.5365(e)(2)/60.5365a(e)(2) even if potential VOC emissions drop below 6 tons per year]
40 CFR, Part 63, Subpart MACT HH,Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility tha: meets either of the following criteria: YN'. Continue-You have indicated th
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior t 3 the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user' (63.760(a)(3))?
2. Is the tank located at a facility that is majors for NAPS? No Storage Tank is not subject MAC
3. Does the tank meet the definition of "storage vessel"`in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"s per 63.761?
S. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage Tank is not subject to MACT NH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the tank meets bath criteria, then review RACT requirements.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name PDC Energy, Inc. _
County AIRS ID 123 History File Edit Date 3/11/2020
Plant AIRS ID 9CE6 Ozone Status Non-Attainment
Facility Name High Plains 25 Sec HZ; LaSalle 25 Sec HZ
EMISSIONS - Uncontrolled (tons per year) EMISSIONS With Controls (tons per year)
AIRS Total
PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO REMARKS
ID VOC HAPs VOC HAPs
Previous FACILITY TOTAL 0.9 0.9 0 0 0 0 153.4 636.4 0 0 177.1 21 .5 0.1 0 1 0.0 0.0 16.5 59.2 0.0 52.2 3 2
Previous Permitted Facility total 0.6 0.6 0.0 0.0 140.5 634.3 0.0 147.4 21 .4 0.0 0.0 0.0 0.0 14.4 58.3 0.0 27.1 3.0
001 18WE1081 Condensate Tanks 410) x 40-bbl 0.1 9.7 0.1 0.3 0 1 0 5 0.1 0 0 No change
002 GP05.CN OCYClI pI UVUI.CU tai TJ luta] t-apcUty 0.0
n n '_
003 GP02.CN ""'�`� J.. YJINL� Jt[G Ill U �, 0.0 , Cancellation notice received on 05/20/2015
004 GP07 Condensate Loadout - LOAD-1 J1 L 0.1 2.6 0.1 0.0 0. 1 10.0 0.1 0.0 No change
005 14WE1095.XP iJl\LJ JIIG I t� 0.1 0.1 1 .1 0.1 23.3 0.0 0. 1 0. 1 1 . 1 0.1 23.3 0.0 No change
006 GP02 RICE: Caterpillar G3306NA 0.1 0.1 18.0 1 .0 18.0 0.4 0.1 0.1 1 .4 1 .0 2.7 0.4 No change
007 GP02.CN RICE: Caterpillar G3306NA 0.0 0.0 Cancellation notice received en 05/19/2015
008 GP02.CN RICE: Caterpillar G3306NA 0.0 0.0 Cancellation notice received on 05,07/2019
009 GP02.CN RICE: Caterpillar G3306NA 0.0 _ 0.0 Cancellation notice received on 05/07/2019
010 18WE1082.CN RICE: Cummins G5.9 0.0 0.0 Cancellation notice received on 07/31/2019
011 18WE1083.XP RICE. Cummins G5.9 0.1 0.1 5.9 1 .0 3.2 0.1 0.5 0 4 0.9 0. 1
012 GP02.CN RICE: Zenith ZPP 644 0.0 0.0 =•ation notice received on 01/03/2020
013 GP02.CN RICE' Caterpillar G3406TA 0.0 0.0 t_.a:::;eilation notice received on 01/03/2020
014 19WE0937 Condensate Tanks (18) x 538-bbl 1.5 382.6 3.0 13.7 1 .5 12.4 3.0 0.4 New CP. previously GP01
015 GP07 Condensate Loadout - LOAD-1 (2) 0.5 128.37 1 .0 2.2 0.6 10 00 1 .0 0.1 no change
016 GP02.CN RICE 143 Hp 0.0 0.0 Cancellation notice received on 01/03/2020
017 GP02 4SRB MDW GM 9.OL SN: 306362 0.1 0.1 16.0 3.5 14.6 0.2 0.1 0. 1 1 .3 0.9 2.6 0.2 Point added and updated on 03/10/2020
018 20WE0216.XP RICE: Cummins G5.9 0.1 0.1 5.9 1 .0 3.2 0.1 0.5 0.4 0.9 0.1 Point added using PTS and form APCD-102
XA External Combustion Devices 0.3 0.3 0.0 4.4 0.1 3.7 0.0 0 3 0.3 0.0 4 4 0. 1 3.7 0.0 Insignificant Source
XA Fugitives 0.4 0.0 0.4 0.0 Insignificant Source; _
XA Produced Water Tanks (2) 0.2 0.0 0.2 0.0 Insignificant Source
0.0 0.0
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
FACILITY TOTAL 0.8 0.8 0.0 0.0 53.6 530.2 0.4 70.2 17.0 0.6 0.6 0.0 0.0 11 .5 36.0 0.4 38.4 1 .3 CO: Minor (OP)
HAPS: Syn Minor n-Hex
HH: Area
ZZZZ: Area
Permitted Facility Total 0.2 0.2 0.0 0.0 36.2 527.8 0.0 36.8 16.8 0.2 0.2 0.0 0.0 5.0 34.9 0.0 9.6 1.2 Excludes units exempt from permits/APENs
A
(A) Change in Permitted Emissions 0.2 0.2 0.0 0.0 -9.4 -23 5 0.0 -17.5 Pubcom & modeling not required based on
change in emissions
Total VOC Facility Emissions (point and fugitive) 36.4 Facility is eligible for GP02 because < 90 tpy
(A) Change in Total Permitted VOC emissions (point and fugitive) -23.5 Project emissions less than 25/50 tpy
Note 1
Note 2
Page 5 of 6 Printed 5/7/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name PDC Energy, Inc.
County AIRS ID 123
Plant AIRS ID 9CEG
Facility Name High Plains 25 Sec HZ; LaSalle 25 Sec HZ
Emissions - uncontrolled (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL (tpy)
!Previous FACILITY TOTAL 1 .8 0.1 0.1 1 .6 2.0 0.1 0.8 14.8 0.1 0.1 21 .5
001 18WE1081 Condensate Tanks (10) x 40-bbl 65.0 485.0 0.3
002 GP05.CN Seven produced tanks total capacity 2200 bbl
003 GP02.CN GM Vortec 5.7 4SRB site rated 87 HP
004 GP07 Condensate Loadout - LOAD-1 ;1 ) 10.0 0.0
005 14WE1095.XP Kubota DG 972-E2 4SRB site rated 22 HP `23 0 5.0 5.0 3.0 0.0
006 GP02 RICE: Caterpillar G3306NA 719.0 30.0 28.0 17.0 32.0 0.4
007 GP02.CN RICE: Caterpillar G3306NA 0.0
008 GP02.CN RICE: Caterpillar G3306NA 0.0
009 GP02.CN RICE: Caterpillar G3306NA 0.0
010 18WE1082.CN RICE: Cummins G5.9 _ 0.0
_
011 18WE1083.XP RICE: Cummins G5.9 78.0 11 .0 6.0 0. 1
012 GP02.CN RICE: Zenith ZPP 644 _ 0.0
013 GP02.CN RICE: Caterpillar G3406TA 0.0
014 19WE0937 Condensate Tanks (18) x 538-bbl 2066.0 3344.0 1388.7 20446.6 85.7 13.7
015 GP07 Condensate Loadout - LOAD-1 ;2) 452.6 3927.2 2.2
016 GP02.CN RICE 143 Hp 0.0
017 GP02 4SRB MDW GM 9.0L SN: 306362 208.8 28.4 26.8 16.1 _ ' 0.2
018 20WE0216.XP RICE: Cummins G5.9 78.0 11 .0 10.0 6.0 0. 1
XA External Combustion Devices 0.0
XA Fugitives 15.8 15.8 15.3 17.6 0.0
XA Produced Water Tanks (2) 7.2 9.0 0.3 9.3 0.0
0.0
TOTAL (tpy) 0.6 0.0 0.0 1 .3 1 .7 0.1 0.7 12.5 0.0 0.0 17.0
Emissions with controls (lbs per year)
POINT PERMIT Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethyibenzene Xylenes n-Hexane McOH 224 TMP TOTAL (tpy)
IPrevious FACILITY TOTAL 1 .8 0.1 0.1 0.1 0.1 0.0 0.0 0.8 0.1 0.0 3.2
001 18WE1081 Condensate Tanks (10) x 40-bbl 24.0 0.0
002 GP05.CN Seven produced tanks total capacity 2200 bbl
003 GP02.CN GM Vortec 5.7 4SRB site rated 87 HP
004 GP07 Condensate Loadout - LOAD-1 (1 ) 5.0 38.0 0.0
005 14WE1095.XP Kubota DG 972-E2 4SRB site rated 22 HP 35.0 5.0 5.0 3.0 0.0
006 GP02 RICE: Caterpillar G3306NA 719.0 30.0 28.0 17.0 ,- 0.4
007 GP02.CN RICE: Caterpillar G3306NA 0.0
008 GP02.CN RICE: Caterpillar G3306NA 0.0
009 GP02.CN RICE: Caterpillar G3306NA 0.0
010 18WE1082.CN RICE: Cummins G5.9 0.0
011 18WE1083.XP RICE: Cummins G5.9 78.0 11 .0 10.0 6.0 0. 1
012 GP02.CN RICE: Zenith ZPP 644 0.0
013 GP02.CN RICE: Caterpillar G3406TA 0.0
014 19WE0937 Condensate Tanks (18) x 538-bbl 67.0 109.0 45.0 664.0 0.4
015 GP07 Condensate Loadout - LOAD-1 (2) 22.6 196.4 0.1
016 GP02.CN RICE 143 Hp 0.0
017 GP02 4SRB MDW GM 9.0L SN: 306362 208.8 28.4 26.8 16. 1 31 .2 0.2
018 20WE0216.XP RICE: Cummins G5.9 78.0 11 .0 10.0 6.0 0. 1
XA External Combustion Devices 0.0
XA Fugitives 15.8 15.8 15.3 15.4 17.6 0.0
XA Produced Water Tanks (2) 7.2 9.0 0.3 3.2 9.3 0.0
_ 0.0
TOTAL (tpy) 0.6 0.0 0.0 0.1 0. 1 0.0 0.0 0.5 0.0 0.0 1 .3
6 19WE0937.CP1 5/7/2020
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