HomeMy WebLinkAbout20200621.tiffCOLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
September 23, 2020
Dear Sir or Madam:
RECEIVED
SEP 3 0 2020
WELD COUNTY
COMMISSIONERS
On September 24, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
SRC Energy, Inc. - Troudt 18-27 Pad. A copy of this public notice and the public comment packet
are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: SRC Energy, Inc. - Troudt 18-27 Pad - Weld County
Notice Period Begins: September 24, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: SRC Energy, Inc.
Facility: Troudt 18-27 Pad
Oil and gas production facility
NENW, Section 27, T6N, R66W
Weld County
The proposed project or activity is as follows: Applicant proposes to operate storage tanks at a well
production facility servicing thirty-six (36) on -site wells. Emissions from the tanks are recycled via vapor
recovery unit (VRU) and vapors are combusted in an enclosed combustor during VRU downtime. During VRU
downtime, enclosed combustors must achieve a control efficiency of 98%.
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 19WE0349 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Bradley Eades
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
Health It Environment
♦�1M4,400
110 Nte
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: 19WE0349 Issuance:
Date issued:
Issued to: SRC Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Troudt 18-27 Pad
123/A038
NENW SEC 27 T6N R66W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
1
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK 1-6
001
Six (6) 400 barrel fixed roof storage vessels
connected via liquid manifold used to store
condensate.
Emissions from the
storage vessels are
routed to a sales
pipeline through the
use of a vapor
recovery unit (VRU).
During VRU
downtime, emissions
are routed to
enclosed combustors
(six (6) IES 96"
combustors)
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days
after commencement of operation under this permit by submitting a Notice of Startup
(NOS) form to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division
Page 1 of 14
C4.44Nue
„y00
COLORADO
Air Pollution Control Division
Department of Publtc Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
of startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1
and can result in the revocation of the permit.
2. 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.)
3. 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.)
4. 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.)
5. 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
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO.
VOC
CO
TK 1-6
001
---
1.2
9.6
5.2
Point
ote: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons
per year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for 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
Page 2 of 14
1M440
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
calculate actual emissions each month and keep a compliance record on site or at a local
field office with site responsibility for Division review.
7. The owner or operator must use the emission factors and calculation methods 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.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK 1-6
001
Recycled via Vapor recovery unit (VRU).
Routed to six (6) enclosed combustors
during VRU downtime
Make: IES Model: 96"
SN: 96-01-75
SN: 96-01-76
SN: 96-01-85
SN: 96-01-86
SN: 96-01-87
SN: 96-01-88
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
II.A.4. )
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK 1-6
001
Condensate throughput
2,726,039 barrels
Condensate throughput
during VRU downtime
408,906 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.
Page 3 of 14
41.
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
10. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU
downtime shall be defined as times when emissions from the condensate storage vessels are
routed to the enclosed combustor(s) rather than the VRU. The total hours of VRU downtime,
total condensate throughput volume and total condensate throughput volume during VRU
downtime shall be recorded on a monthly basis. The owner or operator must use monthly VRU
downtime records, monthly condensate throughput volume records, and the calculation
methods established in the Notes to Permit Holder to demonstrate compliance with the
process and emission limits specified in this permit.
11. On a minimum of an hourly basis, the owner or operator shall monitor each enclosed
combustor for the presence of a pilot light and an operational auto -igniter. These monitoring
records shall be used to calculate enclosed combustor downtime. For any monitoring period
with both VRU downtime and enclosed combustor downtime, it must be assumed that these
events overlapped. During periods without the presence of a pilot light and/or an operational
auto -igniter, emissions directed to the enclosed combustors from the storage tank shall be
assigned a 0% control efficiency. These monitoring records must be maintained for a period
of five (5) years, and a summary of monthly enclosed combustor downtime, monthly vapor
recovery unit (VRU) downtime, and condensate throughput during enclosed combustor
downtime and VRU downtime shalt be provided to the division upon request.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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.) E.) (State only enforceable)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. 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)
15. 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 4 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
16. 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.
17. 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.
18. 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
19. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the O&tMplan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
20. 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)
21. The owner or operator must conduct an initial source compliance test to measure the mass
emission rates of the pollutants listed below, demonstrate compliance with the volatile organic
compounds (VOC) emissions limit in this permit, and to demonstrate a minimum destruction
efficiency of 98% for VOC. During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (Mo) using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Page 5 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(Mi-Mo)/M;
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must include testing
under all operating scenarios of the control device. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Results of the initial compliance tests must be submitted to the Division as part of the self -
certification. Actual emissions calculations must be completed in accordance with the "Notes
to Permit Holder" section of this permit. If the results of the initial compliance test do not
demonstrate compliance with the emissions limits contained within this permit or do not
demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC)
for each operating scenario, the owner or operator must submit to the Division within 60
days, or in a timeframe as agreed to by the Division, a request for permit modification to
address these inaccuracies.
Periodic Testing Requirements
22. On an annual basis, the owner or operator must conduct a source compliance test to measure
the mass emission rates of the pollutants listed below, demonstrate compliance with the
volatile organic compounds (VOC) emissions limit in this permit, and to demonstrate a minimum
destruction efficiency of 98% for VOC. During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (MO using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
Page 6 of 14
alto
COLORADO
Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(Mi-Mo)/Mi
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must include testing
under all operating scenarios of the control device. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Records of the annual compliance tests must be maintained by the owner or operator and
made available to the Division for inspection upon request. Actual emissions calculations
must be completed in accordance with the "Notes to Permit Holder" section of this permit. If
the results of the annual compliance test does not demonstrate compliance with the VOC
emissions limits contained within this permit or do not demonstrate a minimum destruction
efficiency of 98% for VOC for each operating scenario, the owner or operator must submit to
the Division within 60 days, or in a timeframe as agreed to by the Division, a request for
permit modification to address these inaccuracies.
ALTERNATIVE OPERATING SCENARIOS
23. The control device may be replaced with a like -kind control device in accordance with the
requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this
permit or obtaining a new construction permit. A like -kind control device shall be the same
make and model as authorized in this permit. All control device replacements installed and
operated as authorized by this permit must comply with all terms and conditions of this
construction permit. The owner or operator shall maintain a log on -site or at a local field
office to record the start and stop dates of any control device replacement, the
manufacturer, model number and serial number of the replacement control device.
24. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and
serial number of the replacement control device must be filed with the Division within 14
calendar days of commencing operation of a replacement control device under the
Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate
APEN filing fee and a cover letter explaining that the owner or operator is exercising an
Alternative Operating Scenario and has replaced the control device.
25. Within one hundred and eighty days (180) of startup of the replacement control device in
accordance with the Alternate Operating Scenario provision, the owner or operator must
conduct an initial source compliance test to measure the mass emission rates of the pollutants
Page 7 of 14
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
listed below, demonstrate compliance with the volatile organic compound (VOC) emissions limit
in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile organic
compounds (VOC). During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (MO using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(Mi-Mo)/M;
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Records of the initial compliance tests must be maintained by the owner or operator for a
minimum of five (5) years and made available to the Division for inspection upon request.
Actual emissions calculations must be completed in accordance with the "Notes to Permit
Holder" section of this permit. If the results of the initial compliance test do not demonstrate
compliance with the emissions limits contained within this permit or do not demonstrate a
minimum destruction efficiency of 98% for volatile organic compounds (VOC) for each
operating scenario, the owner or operator must submit to the Division within 60 days, or in a
timeframe as agreed to by the Division, a request for permit modification to address these
inaccuracies.
ADDITIONAL REQUIREMENTS
26. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 8 of 14
aNte
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (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.
27. 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
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
28. 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.
29. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide "final" authority for this activity or operation of this source. Final authorization
of the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final
authorization cannot be granted until the operation or activity commences and has been
verified by the APCD as conforming in all respects with the conditions of the permit. Once
self -certification of all points has been reviewed and approved by the Division, it will provide
written documentation of such final authorization. Details for obtaining final authorization
Page 9 of 14
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
to operate are located in the Requirements to Self -Certify for Final Authorization section
of this permit.
30. 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.
31. 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.
32. 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.
33. 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.
34. 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:
Bradley Eades
Permit Engineer
Page 10 of 14
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
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to SRC Energy, Inc.
New synthetic minor permit at a new well
production facility.
Page 11 of 14
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/agcc-reps
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)'
001
Benzene
71432
14,434
43
Toluene
108883
14,710
44
Ethylbenzene
100414
796
2
Xylenes
1330207
5,025
15
n -Hexane
110543
121,514
365
2,2,4-
Trimethylpentane
540841
559
2
ote: 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 12 of 14
latve
COLORADO
Air 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:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission
Factors
When
Emissions
are routed
to the VRU
(lb/bbl)
Controlled
Emission
Factors
During VRU
Downtime
(lb/bbl)
Source
NOx
0.0054
---
0.0054
AP -42
Chapter
13.5
CO
0.0244
---
0.0244
VOC
2.3407
---
0.0468
ProMax
71432
Benzene
0.0053
---
1.1x10-4
108883
Toluene
0.0054
---
1.1x10-4
100414
Ethylbenzene
0.0003
---
5.8x10-6
1330207
Xylene
0.0018
---
3.7x10-5
110543
n -Hexane
0.0446
---
8.9x10-4
540841
2,2,4-
Trimethylpentane
0.0002
---
4.1x10-6
Note: : The controlled emissions factors for this point are based on a control efficiency of 100% while
emissions are routed to VRU and 98% while emissions are routed to enclosed combustors. NOx
and CO emission factors are based on a gas heat content of 2,459 btu/scf.
Actual controlled emissions shall be calculated using the following method:
Monthly Actual Emissions (VOC Ft HAP) = [(Vtotal — VPLX) X EF x (100% — CE)] + [VPLX x EF
where:
Vtotal = Monthly throughput of condensate during VRU downtime (bbl)
VPLX = Monthly throughput of condensate during simultaneous VRU
downtime and enclosed combustor downtime (bbl)
EF = Most recent approved uncontrolled emission factor (lb/bbl)
CE = Permitted control efficiency (98%)
Note: For any monitoring period with both enclosed combustor downtime
(periods without the presence of a pilot light and/or operational auto -igniter)
and VRU downtime, it must be assumed that these events overlapped for
purposes of calculating VPLX . The average hourly throughput, VRU downtime,
and pilot light downtime must be used to calculate the monthly throughput of
condensate during simultaneous VRU downtime and pilot light downtime.
Monthly Actual Emissions (NOx EtCO) = [(Vrorat — VPLX) x EF]
where:
Vtotal = Monthly throughput of condensate during VRU downtime (bbl)
VPLX = Monthly throughput of condensate during VRU downtime while pilot
light was not lit (bbl)
EF = Most recent approved emission factor (lb/bbl)
Page 13 of 14
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
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, NOx, HAP
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.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 14 of 14
Colorado Air Permitt r g Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Far Division Use Only
Review Engineer:
Bradley Fades
Package 6:
395359
Received Date:
3/29/2019
Review Start Date
7/23/2020
Section 01- Facility Information
Company Name:. SRC Energy, Inc.
,County AIRS ID: 123.
Plant AIRS ID: 8038
Facility Name: Troudt1.8-27 Pad:
Physical
Address/Location:
County:
Type of. Facility: Exploration& Production Well Pad
What industry segment Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? - Yes
If yes, for what pollutant? - Ozone (NOx & VOC)
Weld County
Transfer to PDC Energy Inc. reed 02/18/2020
RAME
N, sums,, (5515
Section 02 - Emissions Units Iso Permit Application
!Quadrant
NENW
AIRS Point a
(Leave blank unless
APCD has already
assigned)
001
Egressions Source Type
Condensate Tank
Equipment Name
TK 1-6
Emissions
Control?
Yes
Permit N
(Leave blank unless
APCD has already
assigned)
19WE0349
002
Liquid Loading
LOAD -1
Yes
19WE0350
003
Separator Venting
NGL Flaring
Yes
19W E0351
Section 1 Township Range
27 6N 66
Leave Blank - For Division Use Only
Issuance
Self Cert
Action
Engineering
ft
Required?
Remarks
Permit Initial
1
Yes
Issuance
Permit Initial
1
Yes
Issuance
Permit Initial
1
Yes
Issuance.
Cancelled
Section 03 - Description of Project
The Troudt facility is a well production facility producing condensate, natural gas and produced water from 36 on -site wells. Upon receipt of the application in
March 2019, applicant was requesting a permit to authorize an NGL skid as a gas capture/control system for the condensate storage tanks and produced water
tanks. The application experienced internal delay as the original permit engineer (T. Sharp) resigned his position with the APCD during processing of this
application. I (0. Eades) was assigned to this package in June 2020.
While processing the application in June 2020, applicant indicated that theyno longer wish to permit the NGL skid at the facility and would like to remove this
NGL skid, and replace it with a tank vapor recovery unit package. As such, a permit was never issued for the NGL skid controlling vapors from the storage tanks
and the permit was written for the new configuration described by the applicant (applicant is PDC, who aquired ownership of this faciltiy through:a. company-
wide transfer of ownership fmm SRC Energy, Inc. received by the Division February 2020). Revised calculations to reflect the new configuration of tank controls
was received July 9, 2020. Applicant is requested 90% control for condensate storage tanks vapors routed to combustors during VRU downtime. Requirements
per PS Memo 20-02 will be implemented with the exception of those discussed in the technical analysis notes for Point 001.
Sections 04,
05 &
06 - For Division Use Only
Section 04- Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremel
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: 502 NOx CO
VOC
PM2.5 PM10 TSP
HAPs
Prevention of Significant Deterioration (PSI) ❑ 0 0
1]
❑ ❑
Title V Operating Permits (OP) 0 (] 0
2
0 0 0
0
Non -Attainment New Source Review (NAN5R) 0 _
2
Is this stationary source a major source? No
If yes, indicate programs and which pollutants: 502 NOx CO
VOC
PM2.5 PM10 TSP
HAPs
Prevention of Significant. Deterioration (MD) 0 0 0
0
0 0
Title V Operating Permits (OP) 0 0 0
❑
0 0 0
0
Non -Attainment New Source Review (NANSR) 0
0
Condensate Storage Tanlc(s) Emissions itivei,tory
Section 01 -Administrative Information
(Facility AIRS ID:
123
County
A038 001
Plant Paint
Section➢2- Equipment Description Details
Emissions are recycled by vapor recovery unit (VRUl via close loop system. During VRu downtime, emissions are
Emission Control Device routed to enclosed combustors (six (6) IES 96" combustors) (Serial Numbers: 96-01-25, 96-01-26, 96-01-85, 90-0186,
Description: 96-01-87, 96-01-88)
Requested Overall VOC & HAP Control
Efficiency%: 99.70 0
Section 03- Processing Rate Information far Emissions Estimates
Primary Emissions -Storage Tank(s)
Total (process 01 *process 02)
Actual Condensate Throughput=
Requested Permit Limit Throughput =
`Eff",.{;�';µni,FBarrels (bbl) per year
18"2,]260391 Barrels (hbl) per year
Actual Condensate Throughput While Emissions Controls Operating= Barrels (bbl) per year
Requested Monthly Throughput= "121 Barrels (bbl) per month
Potential to Emit (PTE)
Condensate Throughput =
726,09 Barrels (bbl) per year
Actual Condensate Throughput= '' oE'Barrels (bbl) Per Year
(Requested Permit L ii Throughput= 931131,2,317,138 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating= 0 Barrels (bbl) per year
Requested Monthly Throughput= .,.. Barrels (bbl) per month
Potential to Emit (PTE)
Condensate Throughput =
Requested Overall VOC & HAP Control
Efficiency 56i
Pracess02 (emissions routed to Enclosed Flare)
Actual CondemateThroughput=
(Requested Permit Limit Throughput =
Potential to Emit (PTE) Condensate
Actual Condensate Throughput While Emissions Controls Operating =
Requested Monthly Throughput=
408,906,Barrels (bbl) per yedr
Barrels lbbl) per month
Requested Overall AOC & HAP Control
Efficiency %:
;Barrels (bbl) pen year
Heat content of waste gas
2459.42591 Maisel
Volume of waste gas
emitted per BBL of liquids
produced =
Control Device
Pilot Feel Use Rate:
Pilot Fuel Gas Heating Value:
/bbl
+':75scfh
1153 Btu/scf
MMscf/yr
,.i MMBTU/yr
Actual heat content of waste gas routed to combustion device =
MMBLI per year
Requested heat content ofwaste gas routed to combustion device= ; 1.11 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
section 04- Emissions Factors & Methodoloeles
Will this storage tank emit flash emissions?
MMBTU per year
prouses0lIto .VRU)
Pollutant
Uncontrolled Controlled
(Candensete
Throughput)
(Condensate
Throughput)
Emission Factor -Source
9pOaRcE.F. (includes flash) 1117
Spett6 E.F. (includes flesh)
Sgertfic E. F. (Includes flash)
T}+?.afid E.F. (includes flesh) a
Spedfr E.F. (includes fl h) ;#:a.
8petlEc E.F. (Includes flash)
SPeeifioo F. (Includes flash)
6223.8171 bbl/d
W&B (lb/yr) Flash (lb/yr)
VOC 265453.6086 5051553.7 2.340548
Benzene 362.34 11666.042 0.005295
Taluere 382.34 11825932 0.005396
Ethylbemene 22.434 641.13822 0.000292
Xylem
n-Hexaee
224 TMP
186.32 40009198 0.001843
4549.2 96212.152 0.044575
19.594 446.642 0.000205
2 of 6 C:\users\beades\Desktop\Remote Work\My Packages \Package 395359 (PDCTroudt)\395359 (31Ps)\19WE0349.CP1
Condensate Storage Tank(s) Emwions nvenry
Process 02 (to Enclosed Flare)
[mission Factors
a
Condens to Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
llb/hbll Ilb/bbl(
(Condens
Throughput)
(Condensate
Throughput)
VOC
23407
des flash) E`
'(f rudes0 h)
('rxludesflash)
ncludesfl shl
�nclodes flash)
'(gsludes flash)
Site-' .€'(mcludesflash)
Benzene
0.0054
Toluene
0.0054
1 P
Ethylbemene
0.0003
3. 4.05
Xylene
:0.0038
i.!E u`5
n -Hexane
..0.0446
'a pl
224TMP
0.0002
-. :C.
Pollutant
Control
Device
Emission Factor source
Uncontrolled
Uncontrolled
(Ib/MMBtu)
(lb/bbl)
(waste heat
combusted(
(Condensate
Throughput)
PM1D
0.0075
AP -42 Tab( 14-2(PM10/PM25) D ,.
APA2Tabi 4-2(PM 0/PM 25)
AP-42Chap.r 135Industrial FI (N
AP-42Cheptr 13.51ndusMal Flares (CO
PM2.5
0.0075
NO%
0.0580
CO
0.3100
Pollutant
Pilot Light Emissions
Emission Factor Source
Uncontrolled Uncontrolled
(Ib/MMbtu) (Ib/MMscf)
(Waste Heat
Combusted)
(Pilot Gas
Throughput)
P8510
0.0075
APATTable14-2(PM30/PM25)
PM2.5
0.0075
APAZTtHC0' 2(PM10/PM25) ,.
Sindustrial Fl(NOa)
Industrial Flares (CO) -'
SO6
NO6
00680
CO
,.0,3100
Section 05- EmIstions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/yea.)
Actual missions
uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit limits
Uncontroled Controlled
Item/pearl ltans/year)
Requested Monthly Omits
Controlled
(Ibs/month(
VOC
PMlo
PM2.5
NOx
CO
3MOIS
0.1---
_..
,..
nc
..:
..
Hazardous Alr Pollutants
Potential t0 Emit
Uncontrolled
(Ibs/year)
Actual missions
Uncontrolled Controlled
(lbs/year) (Ibs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (I./year)
Benzene
Toluene.--
Ethylbenzene
Vylene
224 TMP
>_-mblexane
-"
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Regulation 7, Part D,Sertion I.C, D, E, F
Regulator 7, Part D,Section I.G, C
Regulation 7, Part D,Section 11.0, C.1, C.3
Regulation 7, Part D,Section II.C.2
Regulation 7, Part D,Section II.C4.a.(i)
Regulation 7, Part D,Section II.C4.a.(ii)
Regulation 6, Part A, NIPS Subpart Kb
Regulation 5, Part A, NSPS Subpart 0000
NIPS Subpart 0000a
Regulation 8, Part E, MACTSubpart HH
ices a permit
(See regulatory applicability worksheet for de ailed analysis)
Section 02 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emizsionsfactors to estimate emissions?
if yes re the uncontrolleda¢ual or requested emissionseetimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-0
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? This sample should be considered representative which generally meats site-epeciflc and f
collected within one year of theapplication received date. However, If the facility has not been modified (e.g., no
new wells brought on.11ne), then it maybe appropriate to use an older site -specific sample.
It no, the permit will contain an "Initial Compliance' testing requirement to develop a site specific emissions factor based on guidelines in PT Memo 05-01.
Does the company request a control deem efficiency greater than 95% foraflare or combustion device?
yes, the permit will contain and Initial Compliance test condition to demonstrate the destructor efficiency of the combustion device based an inlet and outlet concentration sampling
Section 08 -Technical Analysis Notes
Applicant calculated MMBtu/yr from combustion of waste gas at ECD using flash gas properties (MW, HHVI and standard molar volume (379 scf/Ibmoi).Ths produced a more conservative result than
using the HHV and scf/bbl fromtlie Pramax directly se I will accept rt.
Iwll implement requirements per Memo 2002 for combustor achieving >95% control efficency. However, Iwll not inlcude requirement to meter gas from the tanks since this application was rece'ved
ell before development of this requirementwhich would require sgnfcant facility retrofitting to allow for therequired meter configuraton.
3 of 6 C:\Users\beades\Desktop\Remote Work \My Packages \Package 395359 (PDCTroudt)\395359 (3Ms) \19WE0349.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 09 - Inventory SCC Coding and Emissions Factors
Process 01- Condensate tharughput while VRU is operational
AIRS Pointe
001
5CC Code
Process 02 - Condensate thorughput during VRU downtime
AIRS Point It
001
woor
SCC Code
Oetinitiansfor Drop Crvvn Unto
StorageTank Emissions Factor Options
Condensate State E.F. (includes flash) -Front Range
Condensate State E.F. )includes flash) -West Slope
Condensate State E.F. (includes flash) -Eastern CO
Condensate State E.F. (includes flash) -Rest of CO
Pollutant
PM10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TOP
Uncontrolled
Emissions
Factor Control% Units
0.00 0
0.00 0
0.00 0
55.7 100
0.00 0
0.13 1W
0.13 100
0.01 100
0.04 100
1.06 100
0.00 100
b/0,001 galro0a condensate throughput
b/1,000 gallons condensate throughput
6/1,000 gallonscondensate throughput
b/l,.0 gallons con ems a throughout
b/1,m ns condensate. throughputb/1.000 gallons condensate throughput
h/1.m ore condensate throughput
b/1,10 gallons condensate ovoughput
b/1.000 gaga. condensate oughput
6/1,000 gallons 100..50 throughput
b/1,000 gallons wndensate throughput
Uncontrolled
Emissions
Pollutant Factor Control 56 Units
PM10 0.01 0 /ipso gallons sondema. throughput
PM2.S 0.01 o b/1.000 gallons wndemale throughput
NOx 0.13 0 b/1,mo Sellonscwdemate throughput
VOC 55.73 98 h/1010 gallons condense. throughput
CO 0.58 0 6/1,10 gallons condensate throughput
eenzene 0.13 98 b/1,000 gallons modem.. throughput
Toluene 0.13 98 h/1.mo gallons condensate throughput
Ethylbenzene 0.01 98 b/1.000 gallonsmnaensa. throughput
Xylene 0.04 98 b/1,000 gallons condensate throughput
n -Hexane 1.06 98 b/t,000 gallonswndenszte throughput
224 T0P 0.00 98 b/1.000 gallons condensatehroughput
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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
ATTAINMENT
2.
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)?
Produced Water Tanks have no grandfathering provisions
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 B, Section II.D.3)?
NON -ATTAINMENT _
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
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
2. grandfather applicability)? (U
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 II.D.2(?
'Source requires a per :t
Colorado Regulation 7, Part D, Section I.C-F & G _
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area (Regulation 7, Part D, Section I.A.1)? v
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
3. Is this storage tank located at a natural gas processing plant (Regulation 7, Part D, Section I.G)? N
4. Does this storage tank contain condensate? Y
5. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions (Regulation 7, part D, Section I.G.2)? Y
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))?
s subject to Regulation 7, Part 0, 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 I.D — Emissions Control Requirements
Part D, Section I.E — Monitoring
Part D, Section I.F— Recordkeeping and Reporting
Reg -,u. Ion 7, Section I.G
Part D, Section I.G.2 - Emissions Control Requirements
Part 0, Section I.C.1.a and b — General Requirements for Air Pollution Control Equipment — Prevention of Leakage
Colorado Regulation 7, Part D, Section II
1. Is this storage tank located at a transmission/storage facility?
2. Is this storage tank' located at an oil and gas exploration and production operation , well production facility2, natural gas compressor station' or natural gas processing plant" (Regulation_
3. Does this storage tank have a fixed roof (Regulation 7, Part D, Section II.A.20)? Y
4. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC (Regulation 7, Part D, Section II.C.1.c)? Y
IStorage tank is subject to Regulation 7, Part D, Section.;i, s, -.._ _. C.3
Part D, Section 11.0 — 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, Part D, Section II.C.2.b)? �N
'Storage tank 31.'.:)lect to Reg _ .on 7, Part D, Sec v II.C.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
6. facility that was modified on or after May 1, 2020, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon
'Storage Tahk is not subject to Regulation 7, Part 0, Sec„
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.
7. a facility that was modified on or after January 1, 2021, such that an additional controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon N
If Tank is n< t to at, u D. tt f
40 CFR, Part 6D, 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))? N
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 1,589.874 m3 [-10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfe
3. Was this storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984 (40 CFR 60.110b(a))?
4. Does the tank meet the definition of "storage vessel"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"5 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 pressure6 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 pressure6 less than 15.0 kPa(6(
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 m3 (-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
b. The design capacity is greater than or equal to 75 M3 (-472 BBL] but less than 151 m5 ['950 BBL] and stores a liquid with a maximum true vapor pressure greater than or equal
of subject to NSF:..
40 CFR, Part 60, Subpart OOOO/OOOOa, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
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
1. 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 18, 2015?
4. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
5. Does this storage vessel meet the definition of "storage vessel"' per 60.5430/60.5430a?
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 HH?
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions above 6 tons per year VOC on the applicability determination date, it
should remain subject to NSPS OOOO/OOOOa 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 HI -I, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760)a((2)); OR
A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is
b. delivered to a final end user' (63.760(a))3)(?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"4 in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO?
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 both criteria, then review RACT requirements.
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
SRC Energy Inc - TO to PDC
123
A038
Troudt 18.27 Pad
History File Edit Date
8/18/2020
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
POINT
AIRS ID
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
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
New Facility - No Previous Total
Previous Permitted 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
001
19WE0349
6 400 bbl condensate tanks
0.1
0.1
1.2
3,190.5
5.2
78.5
0.1
0.1
1.2
9.6
5.2
0.2
New individual CP
002
19WE0350
Condensate loadout
0.1
19.2
0.3
0.4
0.1
1.0
0.3
0.0
New individual CP
003
19WE0351
Venting of residue gas from NGL skid
0.0
0.0
cancelled
004
GP08
2 400 bbl produced water tanks
0.0
15.0
0.1
0.8
0.0
5.9
0.1
0.0
New GP08
005
GP02
doosan D21.9L 550 hp
sn:EZYOF802882
0.3
0.3
39.4
3.7
66.3
0.5
0.3
- 0.3
3.7
3.7
8.0
0.5
New GP02 (rec'd 3/29/19)
006
GP02
doosan D21.9L 550 hp
sn:EZYOF802892
0.3
0.3
39.4
3.7
66.3
.0.5
0,3
0.3
3.7
3.7
8.0
0.5
New GP02 (rec'd 3/29/19)
007
GP02
Caterpillar 3508ULB 690hp sn:RBK01E
0.3
0.3
3.3
11.6
20.9
2.3
0.3
0.3
3.3
4.7
0.6
0.6
New GP02 (rec'd 3/29/19)
008
GP02
Caterpillar 3508ULB 690hp
sn:R8K01558
0.3
0.3
3.3
11.6
20.9
2.3
0.3
0.3
3.3
4,7
0.6
0.6
New GP02 (rec'd 3/29/19)
TBD
GP02
Cummins
10.2
3.3
45.9
0.1
1.7
1.2
3.4
0.1
New GP02 (rec'd 9/2020) - Info from APEN recd
9/2020
000
(3F,10
6 400 bbl condensate tanks
0 1
0 1
'1'4WE.0.34// wan :4w, issuance
condensate icadcut
0 0
0 0
14W00350 with tics issu.uan:.v
2 400 bbl water tanks
0.0
0 0
GPOP.t app ren..:a4 vu G; ) 5:/ 10
doosan O2'l ilL 550 Op
0 0
0 0
GP02 p10/41
doosan Del .9L. 550 isa
OP02 pt 000
Caren-l'r01ar 3508ULB F,:e.ep;,
GP02 pt 007
Cate}nllur 3508ULE5 QiSPOOp
GP02 01 006
FACILITY TOTAL
1.3
1.3
0.0
0.0
96.8
3,258.6
0.0
225.8
85.7
1.3
1.3
0.0
0.0
17.0
34.5
0.0
26.2
2.9
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (OP)
HAPS: Syn Minor
HH: area source + no TEG dehy
7777: area source
Permitted Facility Total
1.3
1.3
0.0
0.0
86.7
3,255.3
0.0
179.9
85.4
1.3
1.3
0.0
0.0
17.0
34.5
0.0
26.2
2.8
Excludes units exempt from permits/APENs
(O) Change in Permitted Emissions
1.3
1.3
0.0
0.0
17.0
34.5
0.0
26.2
Note 1
Total VOC Facility Emissions (point and fugitive
(A) Change in Total Permitted VOC emissions (point and fugi ive)
34.5
Facility is eligible for GP02 because < 45 tpy
34.5
•
This history file is being completed for the construction permit and GP application received 3/29/19. Due to Division delays in processing that application, GP10 coverage was needed prior to issuance of 19WE0349, 19WE0350 and 19WE0351 for points 001 and 002. GP10 coverage
was in effect from reciept of that application (2/21/20) until issuance of these permits for these points. Point 005-008 never qualified for GP10 coverage since GP02 coverage begins at reciept of the completed GP02 applications (ie. 3/29/19)
Note 2
Page I of 2
Printed 9/21/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
SRC Energy Inc TO to PDC
A038
Troudt 18-27 Pad
Emissions - uncontrolled (lbs per year
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
e
0
0
0
0
0
0.0
001
19WE0349
6 400 bbl condensate tanks
14434
14710
796
5025
121514
559
78.5
002
19WE0350
Condensate loadout
55
59
3
21
697
3
0.4
003
19WE0351
Venting of residue gas from NGL skid
0.0
004
GP08
2400 bbl produced water tanks
591
467
28
158
330
0.8
005
GPO2
doosan D21.9L 550 hp sn:EZYOF8028&
731
99
94
55
109
0.5
006
GP02
doosan 021.9L 550 hp sn:EZYOF80289
731
99
94
56
109
0.5
007
GP02
Caterpillar 3508ULB 690hp sn:RBK0155'
3731
422
259
126
2.3
008
GP02
Caterpillar 3508ULB 690hp sn:RBK0155£
3731
422
259
22
126
2.3
TBD
GP02
Cummins
276
0.1
009
15510
ii 450 bbl condensate. tanks
0 0
Condensate lhaz014
0 0
2 400 091 wetter tanks
0.0
boosts: 1x21.01. 050 hp
0,0
do01ati 11.21 91. 050 h1>
0 (!
Coleu y b' o 135 811L B 5001,p
4 0
Ceturpffia1 35081,533 tfs0op
b u
0.0
0.0
0.0
0.0
TOTAL (tpy)
4.6
0.5
0.4
7.6
7.6
0.4
2.6
61.3
0.2
0.3
0.0
0.0
85.5
'Total Reportable = all HAPs where uncontrolled emissions a de minimus values
Red Text: uncontrolled emissions o de m111110ue
Emissions with controls (lbs per year)
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (toy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
19WE0349
6400 bbl condensate tanks
43
44
2
15
365
2
0.2
002
19WE0350
Condensate loadout
3
o
1
35
0.0
003
19WE0351
Venting of residue gas from NGL skid
0.0
004
GP08
2 400 bbl produced water tanks
30
23
1
8
17
0.0
005
GP02
doosan D21.9L 550 hp sn:EZYOF802881
731
99
94
56
109
0.5
006
GP02
doosan D21.9L 550 hp sn:EZYOF80289<
731
99
94
56
109
0.5
007
GP02
Caterpillar 3508ULB 690hp en:RBK0166'
388
422
259
22
129
0.6
008
GP02
Caterpillar 3508ULB 690hp sn:RBK0155t
399
422
259
22
'126
0.6
TBD
GP02
Cummins
276
0.1
009
GP i 0
9.9110 001 anndensa)e tanks
0 0
Condensate Inadout
0.0
2 4.00 11tH water tanks
0 0
doesaln 1021 94 500 Op
0.0
doosan 0:721 9L 550 Op
900
Ctololpi0ar a509C11...ri 69009
0.0
Cato, pillar 3'000{)LB 69009
0.0
0.0
0.0
0.0
0.0
TOTAL (tpy)
1.3
0.5
0.4
0.1
0.0
0.0
0.0
0,2
0.2
0.0
0.0
0.0
2.8
2
123AO38
9/21/2(12(1
Addendum to doc #395350
RECEIVED 08-10-2020
Condensate Storage Tank(s) APEN
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19WE0349
AIRS ID Number: 123 / A038 / 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Troudt 18-27 Pad
Site Location: NENW Sec 27 T6N R66W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
Jack Starr
(303) 860-5800
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.
Form APCD-205 - Condensate Storage Tank(s) APEN Revision 12/2019
COLORADO
1 I Department. Public
Health b Emlrommnt
Permit Number: 19WE0349
AIRS ID Number: 123 /A038/001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly -reported emission source
✓❑ Request coverage under traditional construction permit
O Request coverage under a General Permit
O 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 ❑ Transfer of ownership' O Other (describe below)
OR
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
▪ APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: APEN Addendum to control condensate storage tanks with tank vapor recovery
unit(s) instead of a natural gas liquid (NGL) recovery skid
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 12/31/2018
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 Et Production (EEtP) site O Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
ll
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
Yes
No
0
•
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
Yes
No
p
•
If "yes", identify the stock tank gas -to -oil ratio:
0.004701
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
0
•
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
D
•
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
COLORADO
D,artment ol Public
Hcakt 6 Enhranm.nt
Permit Number: 19WE0349
AIRS ID Number: 123 /A038/001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limits
(bbl/year)
Condensate Throughput:
2,271,688
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 46.7 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
2,726,039
RVP of sales oil: 9.3
O External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TK-1
6
2,400
11/2018
12/2018
Wells Serviced by this Storage Tank or Tank Battery6 (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 46235
Troudt 1N -23B -M
■
05
- 123
- 46236
Troudt40N-23C-M
■
05
- 123
- 46237
Troudt41N-23C-M
■
05
- 123
- 46238
Troudt 26C -23-M
■
05
- 123
- 46239
Troudt 8N -23B -M
■
5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider
future process growth. Requested values are required on all APENs, including APEN updates.
6 The MP Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.46459 / -104.76705
✓❑ Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack
ID No.
Discharge Height Above
Ground Level (Feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
O Downward
O Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
O 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
LICOLORADO
3 I ,��
Heaillib iTNronmbit
Permit Number: 19WE0349
AIRS ID Number: 123 /A038/001
[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: VOC and HAPs
Size:
Make/Model: TBD
Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 15
❑ Combustion
Device:
Pollutants Controlled: VOC and HAPs
Rating:
Type:
Enclosed Combustors
MMBtu/hr
Make/Model: 6 x IES 96"
Requested Control Efficiency: 98
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
2,457
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
%
Section 7 - Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 29 psig
Describe the separation process between the well and the storage tanks: 3 -phase separator to gas
buster to storage tanks
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
AO
4I CCOLOROLORDD
Heal t! 6 Environment
Permit Number: 19W E0349
AIRS ID Number: 123 /A038/001
[Leave blank unless APCD has already assigned a permit .# 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? ❑✓ Yes ❑ No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Pollutant
Control Equipment Description
Collection Efficiency
(% of total emissions captured
by control equipment)
Control Efficiency
(% reduction of captured
emissions)
VOC
Enclosed Combustors and Tank VRU
100%
99.70 %
NOx
CO
HAPs
Enclosed Combustors and Tank VRU
100%
99.70
Other:
From what year is the following reported actual annual emissions data? 201 9
Use the following table to report the criteria pollutant emissions from source:
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
Emissionsa
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
2.3407
lb/bbl
ProMax
2,658.70
7.98
3,190.46
9.57
NOx
0.0680
lb/MMBtu
AP -42
N/A
0.94 (DM)
N/A
1.12
CO
0.3100
lb/MMBtu
AP -42
N/A
4.27
N/A
5.10
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
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
❑✓ Yes ❑ No
If yes, use the following table to report the non -criteria pollutant (HAP) emissions from source:
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor?
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
=Os/year)
Controlled
Emissions8
=(Ibsiyectr)
Benzene
71432
0.0053
lb/bbl
ProMax
12,028.34
36.09
Toluene
108883
0.0054
lb/bbl
ProMax
12,258 34
36.78
Ethylbenzene
100414
2.92E-04
lb/bbl
ProMax
663.57
1.99
Xylene
1330207
0.0018
lb/bbl
ProMax
4,187.22
12.56
n -Hexane
110543
0.0446
lb/bbl
ProMax
101,261.20
303.78
2,2,4-Trimethylpentane
540841
2.05E-04
lb/bbl
ProMax
466.24 '
1.40
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.
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019
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Permit Number: 19WE0349 AIRS ID Number. 123 /A038/001
(i e s blank unless APCD has already assigned a permit and AIRS ID)
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) D
ck Starr
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Senior Air Quality Representative
Name (print) Title
Check the appropriate box to request a copy of the:
El Draft permit prior to issuance
Q 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-81
1300 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
Form APCD-105 Condensate Storage Tank(si APEN Revision 12/2019
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