HomeMy WebLinkAbout20202658.tiff .1-, COLORADO
altztr4:4;a 0Department of Public RECEIVED
Health&Environment
AUG 0 4 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632
July 29, 2020
Dear Sir or Madam:
On July 30, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC
Energy, Inc. - Bath-Schmier 32 Sec HZ. A copy of this public notice and the public comment packet
are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I ,n. X 01,
Jared Polis, Governor I Jill Hunsaker Ryan,MPH, Executive Director '# *!
FU{D ,c R.evi ee. ..) cc:PLOP) Nu-Cps),PwomiER/cH/00, 2020-2658
og/OZ/20 OG(S►�)
08/2'/20
*74 Air Pollution Control Division
Qr Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: PDC Energy, Inc. - Bath-Schmier 32 Sec HZ - Weld County
Notice Period Begins: July 30, 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: Bath-Schmier 32 Sec HZ
Well Production Facility
NWSW of Section 32, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: PDC Energy Inc. is requesting permit coverage for eleven (11)
538 barrel fixed roof condensate storage vessels and one (1) surge vessel at a new synthetic minor oil and
gas well production facility located in the ozone non-attainment area.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 20WE0107 Et 20WE0601
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:
Harrison Slaughter, P.E.
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
* COLORADO
Department of Public
1 I -°'+re Health&Environment
Denver, Colorado 80246-1530
� COLORADO
2 Department of Public
Health Er Environment
COLORADO
"§ - Mr Pollution Control Division
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D000,'1,04 0*ub few h€x_It°rwe:rrt�= .
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0107 Issuance: 1
Date issued:
Issued to: PDC Energy, Inc.
Facility Name: Bath-Schmier 32 Sec HZ
Plant AIRS ID: 123/A0B2
Physical Location: NWSW SEC 32 T5N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
Eleven (11) 538 barrel fixed roof Enclosed
TK-1 001 condensate storage vessels connected via Combustor(s)
liquid manifold.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www,colorado,gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
Page 1 of 10
COLORADO
400
rt
Mr Pollution control Division
- a
Dtl t r f11 PUNK.p ealtil gr to rt true a
Dedicated to protecting and improving the health and environment of the people of Colorado
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. The operator must 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,� VOC CO Type
TK-1 001 --- 1.0 9.7 2.2 Point
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria pollutants, must be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder must calculate actual emissions
each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
6. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TK-1 001 Enclosed Combustor(s) VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
Page 2 of 10
COLORADO
Air Pollution Control Division
COME
Cie:, •VrIell a Pub e he its b
Dedicated to protecting and improving the health and environment of the people of Colorado
available to the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Process Parameter Annual Limit
ID
Condensate
throughput routed
directly from the
01 three-phase 192,186 barrels
TK-1 001 separators to the
condensate storage
vessels
02 Combustion of pilot 1.7 MMSCF
light gas
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility,for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
12. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.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
Page 3 of 10
; COLORADO
€ Air Pollution Control Division
DPH�
DeOar;rrler"r;ci Pub o Hear b Lrporururt n
Dedicated to protecting and improving the health and environment of the people of Colorado
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
13. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING & MAINTENANCE REQUIREMENTS
16. Upon startup of this point, the owner or operator must follow the most recent operating and
maintenance (OEM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 4 of 10
_ , , COLORADO
Wrof Mr Pollution Control Division
Del:dirt o 1' bk.Health 6 ZrivinYvne",;
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 (NOx) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five(5) tons per year, whichever is.less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Emissions - tons per year
Facility AIRS Equipment Current
Equipment Point Descrip tion Pollutant
ID Threshold Permit
Limit
Condensate
TK-1 001 Storage
Vessels NOx 50 20.3
VOC 50 36
LOAD-1 002 Hydrocarbon
Loadout
Page 5 of 10
ICOLORADO
4, , Air Pollution Control Division
COPHE
De≥. IftbrrIl o F'ub c t fe8ltti Er trtvrrLt+fnv,;
Dedicated to protecting and improving the health and environment of the people of Colorado
ENG-1 003 SI RICE
ENG-2 004 SI RICE
ENG-3 005 SI RICE
ENG-4 006 SI RICE
ENG-5 007 SI RICE
ENG-6 008 SI RICE
GEN-1 009 SI RICE
GEN-2 010 SI RICE
Surge 012 Separator
Vessel
Insignificant
Sources
Note: The insignificant sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
21. 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.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
23. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
Page 6 of 10
a z•-� ; COLORADO .
Air Pollution Control DivisionCDFH
Cit-tra voeali 7 Pub.Y.Fteiilrh S twor�-rrn
Dedicated to protecting and improving the health and environment of the peop'e of Colorado
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc.
Permit for eleven (11) condensate storage
vessels at a new synthetic minor oil and gas well
production facility.
Page 7 of 10
' COLORADO
Air Pollution Control Division
i Dt.;,-arirrt,”:10,Ruts r_Healtri t trtv?rL?tint••,;
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 894 45
Toluene 108883 1,155 58
Ethylbenzene 100414 20 1
001 Xylenes 1330207 548 28
n-Hexane 110543 8,481 424
2,2,4- 540841 27 2
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Process 01: Condensate throughput routed directly from the three-phase separators to the storage
vessels
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 9.699x10-3 9.699x10-3 TNRCC
Page 8 of 10
,, , _ y ...., ICOLORADO
4140141PAir Pollution Control Division
DP HE
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 1.936x10-2 1.936x10-2 TNRCC
VOC 2.0003 1.0x10-1 ProMax
71432 Benzene 4.652x10-3 2.326x104 ProMax
108883 Toluene 6.009x10-3 3.004x10-4 ProMax
1330207 Xylene 2.852x103 1.426x104 ProMax
110543 n-Hexane 4.413x10-2 2.206x10-3 ProMax
Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency
of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific
pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax
simulation was obtained from the outlet of the low pressure separator for the Bath-Schmier 11N well
on 11/08/2019. The sample pressure and temperature are 25.3 psig and 133°F respectively. 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 molecular weight of 43.5316 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole,
a VOC mole % of 61.054746% and a heat content of 2,461.3452 Btu/scf. Actual emissions are
calculated by multiplying the emission factors in the table above by the total condensate throughput.
Process 02: Combustion of pilot light gas
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/MMSCF lb/MMSCF
NOx 77.25 77.25 AP 42 Chapter
13.5
CO 352.16 352.16 AP 42 Chapter
13.5
VOC 6.13 6.13 AP-42 Chapter
1.4 Table 1.4-2
Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42
Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a
heat value of 1,136 Btu/scf. The VOC emission factor in the table above was obtained by multiplying
the AP-42 Chapter 1.4 emission factor by a ratio of 1,136 Btu/scf to 1,020 Btu/scf. Actual emissions
are calculated by multiplying the emission factors in the table above by the total fuel flow of the
pilot light gas. Pilot light gas fuel flow is based on a constant rate of 15.6 scf/hr. There are a total
of twelve combustors used to control emissions from the condensate storage vessels. As a result, the
total pilot light gas fuel flow is 187.2 scf/hr.
Total actual emissions are obtained from the sum of emissions resulting from the storage vessels
and combustion of waste gas from the storage vessels (process 01) and the combustion of pilot light
gas (process 02).
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
Page 9 of 10
a _ ",.....t. COLORADO
Air Pollution Control Division
east E I
Dk-arartt eil d Pubtr_t feels b Cn r,PTrt i;
Dedicated to protecting and improving the health and environment of the people of Colorado
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, CO >t NOx
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC a NOx
MACT HH Area Source Requirements: Not Applicable
Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
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
a . } COLORADO
Air Pollution Control Division
CDPH6 I
I �rt,:7:0' 'uL I, He31th Er s.nvfrC±irtle^a
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0601 Issuance: 1
Date issued:
Issued to: PDC Energy, Inc.
Facility Name: Bath-Schmier 32 Sec HZ
Plant AIRS ID: 123/A0B2
Physical Location: NWSW SEC 32 T5N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
Equipment Description
ID Point Description
Natural gas flaring from one (1) surge Enclosed
Surge Vessel 012 vessel during vapor recovery unit (VRU) Combustor(s)
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
this specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self-
certify compliance as required by this permit may be obtained online at
www.colorado.Rov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
Page 1 of 11
.,, , ; COLORADO
Air Pollution Control Division
CDPHE E
c: Itttteht 0'Fucr_tied'l7 Er Envkt-vsne l
Dedicated to protecting and improving the health and environment of the people of Colorado
months or more; (iii) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III.F.4.)
3. The operator must 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:
AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO), VOC CO Type
Surge Vessel 012 --- 0.4 4.8 0.8 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits, for criteria pollutants, must be determined on a rolling
twelve (12) month total. By the end of each month a new twelve month total is calculated
based on the previous twelve months' data. The permit holder must calculate actual
emissions each month and keep a compliance record on site or at a local field office with site
responsibility for Division review.
6. The owner or operator must use the emission calculation methods and emission factors found
in the Notes to Permit Holder to calculate emissions and show compliance with the limits
contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice
(APEN) and receive a modified permit prior to the use of any other method of calculating
emissions.
7. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants
ID Point Controlled
Emissions from the surge vessel are routed
Surge Vessel 012 to Enclosed Combustor(s) during Vapor VOC and HAP
Recovery Unit (VRU) downtime
Page 2 of 11
ICOLORADO
Air Pollution Control Division
5170` f C;eaa'"a?t ,s:a'PubI, t fe_+Irh tr= v.tCrUrle-''.
Dedicated to protecting and improving the health and environment of the people of Colorado
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rates must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part B,
Section II.A.4.)
Process Limits
Equipment ID AIRS Process Parameter Annual Limit
Point
Surge vessel hydrocarbon
Surge Vessel 012 liquid throughput during 96,093 barrels
vapor recovery unit (VRU)
downtime.
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 rotting 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 surge vessel vapor recovery unit (VRU)
downtime on a daily basis. Surge vessel VRU downtime shall be defined as times when waste
gas vented from the surge vessel is routed through the storage vessels to be controlled by the
enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total
hydrocarbon liquid throughput routed through the surge vessel during VRU downtime, and
total hydrocarbon liquid throughput through the surge vessel shall be recorded on a monthly
basis. The owner or operator must use monthly VRU downtime records, monthly surge vessel
hydrocarbon liquid throughput records and the calculation methods established in the Notes
to Permit Holder to demonstrate compliance with the process and emission limits specified in
this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. 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
Page 3 of 11
O
` Ai Pollution
O R A Q of Division
CDPHF
V a•trrlent cr. t Erporcnrrle-5;
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
13. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or
after August 1, 2014, gas coming off a separator, produced during normal operation from any
newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be
routed to a gas gathering line or controlled from the commencement of operation by 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.
14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of this point, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to the 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
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
Page 4 of 11
a , COLORDO
j Air Pollution Contro Division
DPH
!
- C.t'• r',�iLe It Pujj,HeJlrh£3 Lt1wFrLfUrit'"-,?
Dedicated to protecting and improving the health and environment of the people of Colorado
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
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.
19. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Pollutant Emissions - tons per year
Page 5 of 11
atfg2:000LORADO
Air Pollution Control Division
CDPHE
Dtdk3rl rre'e 0'Pub tie-1Ui 6 Erven- rtle-,1
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility AIRS Equipment Current
Equipment Point Description Threshold Permit
ID Limit
Condensate
TK-1 001 Storage
Vessels
LOAD-1 002 Hydrocarbon
Loadout
ENG-1 003 SI RICE
ENG-2 004 SI RICE
ENG-3 005 SI RICE
ENG-4 006 SI RICE NOx 50 20.3
ENG-5 007 SI RICE VOC 50 36
ENG-6 008 SI RICE
GEN-1 009 SI RICE
GEN-2 010 SI RICE
Surge 012 Separator
Vessel
Insignificant
Sources
Note: The insignificant sources do not have permit limits. However, the PTE of these sources
(excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR.
GENERAL TERMS AND CONDITIONS
20. 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.
21. 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 6 of 11
a ,
Air' COO
Luti Rn A DControDivision
CDPHE
I Cexa'trt5 =:[0'Ruble_F re JUi C r ruivne-
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.
22. 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.
23. 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.
24. 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.
25. 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.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Harrison Slaughter, P.E.
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc.
Permit for one (1) surge vessel at a new
Page 7 of 11
COLORADO
Mr Pollution control Division
Deoac ie+at o Putixc tfeedth&trMi vune-f
Dedicated to protecting and improving the health and environment of the people of Colorado
synthetic minor well production facility.
Page 8 of 11
Aire g _ ,, ..,.. , , COLORADO ution Control Division
CDpHE
CSC 3r>rt),:e+'PuLh_HB91rih&Enwru,'me—
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See:.https://www.colorado.gov/pacific/cdphe/aqcc-reps
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the sources operates at the permitted
limitations.
Equipment AIRS Uncontrolled Controlled
ID Point Pollutant CAS # Emissions Emissions
(lb/yr) (lb/yr),
Benzene 71432 447 23
Toluene 108883 578 29
Ethylbenzene 100414 10 1
Surge Vessel 012 Xylenes 1330207 274 14
n-Hexane 110543 4,241 212
2,2,4-
540841 13 1
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Point 012:
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 7.75x10-3 7.75x10-3 TNRCC
Page 9 of 11
COLORADO
Mr Pollution Control Division
CAPNE
i Orrter5l&Pubi_Ffeett 6:rrvinxvne.i
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
CO 1.55x10-2 1.55x102 TNRCC
VOC 2.0003 1.0x10-1 ProMax
71432 Benzene 4.652x10-3 2.326x1O4 ProMax
108883 Toluene 6.009x10-3 3.004x10-4 ProMax
1330207 Xylene 2.852x10-3 1.426x10-4 ProMax
110543 n-Hexane 4.413x1O2 2.206x10-3 ProMax
Note: The controlled emissions factors for this point are based on the enclosed combustor control
efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site
specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax
simulation was obtained from the outlet of the low pressure separator for the Bath-Schmier 11N well on
11/08/2019. The sample pressure and temperature are 25.3 psig and 133°F respectively. The TNRCC
Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138 lb/MMBtu and
0.2755 lb/MMBtu respectively)in the table above were converted to units of lb/bbl using a GOR of 22.83
and a heat content of 2,461.345 Btu/scf. Actual emissions are calculated by multiplying the emission
factors in the table above by the total hydrocarbon liquid throughput routed through the surge vessel
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 yecent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, CO a NOx
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC Et NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the following website: 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
Page 10 of 11
z• COLORADO
Mr Pollution Control Division
carer
OED.9t-rte,11 ia'Vubls_Beall i 6:rwr Me-',3
Dedicated to protecting and improving the health and environment of the people of Colorado
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 63.1440-616175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Harrison Slaughter
Package#: 422414
Received Date: 12/2/2019
Review Start Date: 4/8/2020
Section 01-Facility Information
Company Name: PDC Energy,Inc. Quadrant Section Township Range
County AIRS ID: 123 NWSW 32 5N 64
Plant AIRS ID: A062
Facility Name: Bath-Schmier32 Sec HZ
Physical
Address/Location:
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? -Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRs Point It Permit if
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
Emissions Source Type Equipment Name Action
APCD has already Control? APCD has already (4 Required? Remarks
assigned) assigned)
Permit Initial
001 Condensate Tank TK-1 Yes 20WE0107 1 Yes Issuance
Section 03-Description of Project
PDC Energy,Inc.(PDC)is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non-
attainment area.With this application,the operator is requesting permit coverage for a surge vessel,condensate storage vessels,hydrocarbon liquid loadout
and engines.The hydrocarbon liquid loadout and engines are requesting general permit coverage.This analysis only evaluates the condensate storage vessels.
This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section B 3.a.j.'Additionally,
the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy(CO AQCC Regulation
3,Part B,Section II.D.2.3.).
Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements,and the change in VOC
emissions as a result of this project is greater than 25 tpy.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑I ❑ ❑
Title V Operating Permits(OP) ❑ D LI M ❑ DOD
Non-Attainment New Source Review(NANSR) 0 ❑J
Is this stationary source a major source? No
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) COLD ❑ ❑
Title V Operating Permits(OP) ❑ ❑ ❑ ❑ ❑ ODD
Non-Attainment New Source Review(NANSR) ❑ ❑
Section 01-Administrative InformatMn
IFacdrty AIRS ID: 123 A0B2 x:001
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Eleven 41)530 barrel fixed roof condensate storage vessels connected ale liquid manifold.
Description:
•
Emission Control Device Enciosed CombOstOr(n
Description:
Requested Overall VOC&HAP Control Efficiency h: 95.0
500000 03-Processing Rate Information for Emissions Estimates
Primary Emleelons-Storage Tank(s)
Actual CondensateThroughput= ;,';150450-0::.Barrels(501)per year
Requested Permit amp Throughput= ener;290186;0iBaneis Mal)Per Year Requested Monthly Throughput= +.... Bartels(bbl)per month
Potential to Emit(PTE)Condensate Throughput N :"{.t- ¢c"I
-19O1860 Bartels(bbll per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= "„Btu/scf
Volume ofwastegas emitted per BBL of liquids
produced= sd/bbl
Actual heat content of waste gas routed to combustion device= 11,256.4400 MMBTU per year
Requested heat content of waste gas routed ft combustion device= MMBTU per year
Potential to Emit inn)heat content afwastegas routedtecombustion device= MMBTU per year
Control Device
Number of Combustors: 32
Plot Fuel Use Rate: 15.6 scfh : MMSCf/yr
Plat Fuel.Gas Heating Value: 1136 Btu/scf MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will thls storagetank emit fish emissions? -7)
ProMax Flow Rate 240,233.00 bbl/year
Pollutant Flash Gas(Ib/hr) W&0 Gas Total Waste Gas Source
pb/hr) Rate(Ib/hr)
VOC 36.40311942 :.18.45388935 ProMax
Benzene :0.0963978' 0.0313701 .. PreMmi
Toluene 0.122277 0.0425042 PrcMax
Ethylbenzene 0.0020785 0.000788856 ProMax
Xylenes 0.0521374 0.0260604 _.. ProMax
n-Hexane 0.813323 0396839 ProMax
2,2,4-TMP .;0.00253561 0.00120276 Prof..
Emotion Factors Condensate Tank
Uncontrolled Controlled
Pollutant (Ib/bbil (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VIC 2.00034 She.SpeclRc EF.(includes flash)
Benzene 4.6517E-03 - Site Specific E F.(includes flash)
Toluene 6.0087E-03 Site Specific ET.(includes flash)
Ethylbenzene 1.0456E-04 Site Specific E F(includes flash)
Xylene 2.8515E-03 Site Specific E.%(Panties flash)
n-Hexane 4.4128E02 Site Specific E.F.(Includes Hoch)
224TMP 1.3632E-04 Site Specific E.F.(includes Hash)
Control Device
Uncontrolled Uncontrolled
Pollutant )Ib/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 AP-42 Table 1,4-2(PM10/PM 2.5) ,
PM2.3 0.0075 AP-42 Table 1.4-2)PM10/PM2.5)
NDx 0.1380 - TNRCC'.Flare Emissions Guidance iSot)
CO 0.2755 _ - TNRGC Flare Emisions Gudance{CO)
Pilot Light Emissions •
uncontrolled uncontrolled
Pollutant (lb/MMBtu) (Ib/NEMscf) Emission Factor Source
[Waste Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 -- AP-R2Tablel4-0(PM10/PM.25)
PM2.5 :.0.0075 - AP-42 Table 1.44 LPM30/PM25)
Nox 0.0680 AP-42 Chapter 13.5 Industrial Flares(Non)
CO : 0.3100 AP.42Chapterl35tndustrial Flares(CO)
VOC 0.0054 OP42Tabie i4-2(000)
Section 95-Emissions InVentore
Potential to Emit Actual Emissions Requested PetmH Limits Requested Monthly Limits
Crkeda Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/veep (tons/year) (tons/year) (tons/year) (Ibs/month)
VOC
PM10
pM2-5
NOx ..
CO
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (lbsfyearl tics/year) Ilbs/year) (IM/year)
Benzene .. ., ..
Toluene ..
Ethylbenzene - 0.637
Xylene 22 334
n-Hexane -i.3.:6
224 TMP ... .:..t-b;
section 06-Regulatory Summary Analysis
Regulation 3,Parts A,8 ..a..-equlrOt 3:-.......
Regulation 7,Section 011.0,0,6
Regulation 7,Section XlLG,[
Regulation 7,Section XVII.B,C.1,C.3
Regulation',Section XVII.c.2 Menem tank is erinactm
Regulation 6,Part A,NSPS Subpart Kb -.to 500,,
Regulation 6,Part A,NIPS Subpart 0000 +NSi-
NSPS Subpart 0000a
Regulation 8,Part E,MAC]Subpart BR
(See regulatory applicability worksheet far detailed analysis)
2 of 4 C:\Users\hslaught\Desktop\123A002\DOW E010T.CPl
Condensate Stora e Tanks,Enlissi rs inventor,/
Section 07-Initial and Periodic Sampling and Testing Requirements
Ooes the company me the state default emissions factors to estimate emissions? y
If yes,are the uncontrolled actual or requested emissions estimated to be greater h equal to 80 tons VOC per year? _N/A-the operator developed site specific emission factors.
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a tee specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions? _'.
If yes and if there are flesh emissions,are the emissions factors lamed on a pressurized liquid sample drawn at the
facility being permitted?This sampleshould he considered representative which generally means site-speak and
collected within one year f the application received date.However,if the facility has not been modified(eg,no new # t s
wells brought online),then site-specifict may be appropriate to use an older site-specific sample.
If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelitem in PS Memo 0501.
Dag the company request a control device efficiency greater than 95%Mr a flare or combust On device? :N
if yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling
section 09 Techncal Analysis Notes
1.Typically,the secondary combustion ions are calculated using the waste gas flow rate and heat content predicted by the model used to establish theshe-specificions factors,Based on the
PeeMax simulation the total waste gas flow rate was predicted to be 0.01502302 MMscf/day(Flash and W&B ges).Additionally,amavetage heat content was determined using the heat content of the flash
gas stream(2429.598tu/scf)and the W&B stream(2525.268tu/scf)and the following equations:
Average Heat Content,t(2429.59BtU/Scf)"(0.0100881 MMscf/day)/(0.01502302MMscf/day)]+[1252f.26Btu/scf)'(0A0493492MMscf/day)/(0.01502302MMscf/day)l=2461.345181Btu/scf
Using the Information,the yearly heat input of the gas would be calculated as follows:Heat Input(MMBtu/yr)=(0.01502302MMsef[day)•(365dey/year)(2461:345181MMOte/MMscf)•(15D,155
bbVyeee)/(240,233bbVyear)=8,997.58 MMBtd/year.Usingthk value,the actual Not and CO emissions would be caluated at(2.62 tpy and 1.24tpy respectively.
The operator used the following equation to caialatethe actual-annual heat input:Heat Ieput(MM9tu/yr)=[Uncontrolled VOC(toe/yr)]•[20001b/ten)/(M W(ib/Ib-moI)]•f379.415cf/Ib-moq•fl/VOCmol
%)"[Heat Content(Btu/scf))(3MMBtu/1,000,W0BLuj.The operator expressed the velum for molecular weight and vOC mol%used in the equation were obtained from the flash gas stream and the heat
nceht was obtained from the average oftheflash gas stream and the W&B stream in the ProMax simulation provided In theappgation.The values used inthe equatmn am as follow:0)Molecular
weighf:435316Ib/Ib-mot,(01000 mai%:61.05474501%,(ii)Heat Content:2461.3451818tu/scf.Usingthese values,the operator calculated a heat input of 11,256.44MM8a/yr.5ince this value is more
conservative than the value calculated above using prescribed methods,owiil be used for permitting purposes.
0 The sitespec'dicsemple used toestablish emissions fectorsforthis source was obtained within a year of the application.The sample was obtained from thee.Bath-5chmier 11N well an 11/08/2019.This
well is one of the eleven new well drilled atthsfaciihy.Addnhooally,the sample was obtained after al(the wells at this facility began production.As a result,the permit will not require initial testing in
order to obtain a sitespeciticsample.It should he noted thafthe sample indudw sample probe temperature and presure in conjunction with gauge pressure and temperature.According to lab
information,the sample probe temperature and pressure are obtained using lab equipment during the sampling process.These vats are expected to be more accurate compared to the gauge values and
are acceptable for use in the simulation to estahfth site specific emission factors.
3 Please referencethe APEN submitted an 12/02/19 for a list of the eleven new wells at this facillty.The wells assouated with thistank battery were fractured.August 2019 and began production in
September 2019.Tee of the eleven wells atthe facility produce from the Niobrara formation.The eleventh well produces from ttr arlile,Collett and Fort Hays formations.
0.The permit willnot contain initialo periodic opacity testing for the enclosed combustor)s)becausethe O&M plan approved for ads source requires weekly visible emissions observations of the
enclosed combustor(s).
5.Emission factors for ethylbenaene and 2,2,4-TMP will not be included in thepermrt because emissions are below APEN reportingiiresholds(i.e.<250 lb/year).
6.The operator provided the followinginformation regarding the 300 bbl LO control tank fisted on thefadiitydl g mt"The yesselert the facility diagram labeled"300 bbl l0 Centro)Tank"is the knockout
tank fo r the focdityslamdoutflore.Vapors from truck loadout are first rooted to this tank,and then to theflore dedicated w controfFmg loodou octivitles.Any einissians associatedwlth this tank are
accounted for by theloadout emissions.Iris not normal operation jot ANY condensate to enter this tank.(nitre unlikely event fiqusdmndensoteoccurs within thetank,either from the condensing a.
or theflooding of the tank-truck vapor line due 000verfillinw the liquid is immedietelytroraf rredfrom the knockout tank to the comfe sate storage tanks."This information indicates any potential
emissions associated with this vessel are appropriately accounted for In the application.
7.Athroughput limit is included in the permhfor pilot combustion.Emission factors and calculation methods for pilotllght combustion emissions are also included In the notes to permit holder.This
information is included in the permit because pilot light emissions contribute to the overall emissions from this source.Addkionally!t is important to include the information because throughput tracking:
and emission calculation methods are different than those used to estimate emissions based on the condensate throughput.The clarity is important for accurately quantifying actual emissions at this
far ifu,
e.According to the application,`the hydrocarbon liquid flowstoa surge vessel,which further sepaats the fluldphxse.The hydrocarbon liquid then flows toe third partypipelinete besold via a Lease
Automatic Custody Transfer(tACijunit.Artiness when the surge vessel is not operational,the condensate flows to eleven(11)538bbl condensate storage vssets.The tank vapors are sent to the
enclosed combustors."Based on the facility design,emissionsocwr when the hydrocarbon liquid'¢sent to the storagevessels ratherthan the surge vessels and when the surge vessel VRU is down.tt was
determined that the storage vessels and surge vessel do not meet the APElggouping requirements and must be permitted separately.This determination was made fore couple reasons.Flist of which is
tit tthesurge vemel and storage yes eb are two distinct emitting units that h ediifferent`control scenarios and distinct throughput values.Further,the regulatory applicability for the storage vessels is
distinctly different from that of the surge vemeLThe surge vwset is not classified or defined as a 5toagevesoei and would therefore sot be regulated as such under NSPS Kb,MOPS 0000/0000e or
Regulation 7.Instead,the surge vessel would be classified au a separatarf0r Regulation 7 requirements.Th's permit only addresses the th roughput routed to the storage vessels and the rguking
emissions.Based wattle fadktydescriptian and discussions with the operator,the hydrocarbon liquid esent directly to the storagevssels during surge vessel and lACTdawmime.The hydrocarbon liquid
is never routed to the surge vessel prof to being routed to the storage'vg els.The operator Indicated that the surge vessel condensate through.and condensate tit r0ughput:routed directly to the
storage vosek aredktinct and tracked separately.
9.The operator indicated that their SCALIA system dktinctly measures the volume of hydrocarbon liquid sent to either Me sage vessel or the storage vessels:Asa result,the hydrocarbon liquid
throughput for the surge vessel andstorage vessels an be determined independently and accurately.
i.I n the event the g easels not operational and/or thebACf unit is not available,the operator indicated that the hydrocarbon liquid from the inlet separators Is routed directly to the storage
vessels.Duet°the facility dsign,the site specific sample used to develop emission factors and estimate emissions was deemed acaptabie because d was taken from the.let of the heated separator
for the Oath-5chmier 13N well.5incethe sample was taken from the outlet of the separator that sends liquid directly to the storage vessels,initial sampling is oat required in the permit.
11.The operator provided a copy of the°NOS that was submitted electronically to the DivMon for the source on 03/26/2020.As a result,the standard condition requiring subm#tal of a Notice of Startup
for the source upon issuance of the permit was removed from the permit.
12.The sample provided in the application and used to stimateemeslons from this source lists a gauge pressure of 55 pale and a pmbe pressure of 25.3 pslg.The operator indicated that the large
discrepancy is due to a typo in the report provided by the lab.The operator confirmed thet theaverage operating pressure for the separators at the facility is around 253 paig,Therefore the ProMax was
correctly set up using the probe pressure(25.3 prig)listed in the sample report.
13.The source is not subject to the measurement system requirements in Regulation 7 Part 6Section 11.0.4 because the storage vssee were constructed before OS/01/2020.
14.The operator was provided with a draft permt and AP EN redline to review prior to public comment.The operator reviewed bottcdocuments and expressed they had no Comments
Section 09-Inventory SCC Coding and Emissions.Factors
Uncontrolled
Emissions
AIRS point# Process if SCC Code Pollutant Factor control%Units
Mk.0014IFlgaeAemnt nkp,C demWtgvroklrgay0004thineil hleflasses PM301 b/1;000 gallons condensate throughput
PM25 b/1,000 gallons condensate throughput
NOx b/1,000 gallons condensate throughput
nob -. _. -- h/1,000 gallons condensate throughput
CO b/1,000 gallons condensate throughput
Benzene 6/1,000 gallons condensate throughput
Toluene -- 1/1,000 gallons condensate throughput
Ethylbenzene 1/1,000 gallons condensate throughput
Oylene b/1,000 gallons condensate throughput
n-Hexane b/1,000 gallons condensate throughput
224'IMP - b/1,o00gallons condensate throughput
sofa C:\Users\hslaught\Desktop\ldvaoo2\20W E0107.CP1
Condensate Tank RegtdaterVAnalysis Worksheet
The regulomry requirements below ore determined hosed on requested emissions.
Colorado n.:Wall Perna itaaulranuots
I aewowMd a,ortiees.lutantsfnom.Individual source pmmtlunzTpr(Rgwton 3,vamp seams
2 s.constryction date 1 date)prior // na rimMod.,aHer12/31/1002[seeps memo 05010dnt o0,lax antll oddlUau..an.g+andWerappleabltYV
3 Aretotal facility u ssm TM NOs greater thanlo Tin era]emissions greater than l0rrr wauwto Ihpa)?
1.Am uncontrolled olld..srons from v enter,nau tools Oom+nn rnar.d,ulsourmgreater mnnpr tB.eelalon3,pan A,smLmnn..1ap Yes Source fa.annpex.n.a menatq elan
ate Iservee date)prior to 12/30/2002 and not mdlgd after 12/31/2002 pee P5 memo 05-01 De hritlom 1.22 wd2,14 and Sectlonx for+aalnanal gdaance or&MIAMI appkegboltyl? No Go to nog quest.n
3.Are totalnalmin uncomroedvc emissions greaser-Manx my, grmterthan 5TPY m m emissions greater than10•PY(PegulatIon3.Parte.seavonuo.21? Ya so.meaegd p n
storage
og
card area n a peat/a -.uNs pmJ.a xt.
2.Is this storage tank lomtdat anedl and pg�mplmotm and prducdonopa�w'�natuM gas mmpreroraalt anernaur+l gas drip suxeni ou Fave Indlratd tFefanlhytyp.otM1epmj+attsnmmary.nmma.y
3. smbzo lttt tie dam urea ss elect
Sactionn.s1 General Requirements for Ak Pallutrom Control Eq...-Preventlan Leakage
UR.X11.3.-Monitoring
section.,0.eaordkeeping and naPort,ng
rolarade BeeJatlonT s+don all I.Is MA storagetank lomted 'he 6-hr ozonecomool area or any one ttainment o.or anaTament/molntenance , continue- Medotta,nmen,sta..,Me 6miss.
lag 'd�qumd masgnong and have uncontrolledaaua emissionsaatethan oxt we 2.Is Mk storage tank lomted at o..ral gas p.n.{plant? •. 'Storage Tank snot ruy.aam Regulation 7,..n 41.6 vats nay.lauted(na yyp project summary et.
3.°moth's storage tank Mtn',Iasi, : w t per year ?
Pollution Control Equkarrient—Preuentfon d Leakage •
ralerede peeMation>.3e.onxvQ
1.Is this tank located at a+ .a/storage facility? .. +
2.Is tils condensate storageMnli located at anoll and gas bratlan and produnionoperation,wal production faauy',natural gas wrniaresorstacOon.ornotural gas proomingplant. haw Indicated facility type on protect summary sheet.
condensate4.Are uncontrolled atons perV.,.Vac, Source Is salmi,.to parts e(Rquat en T,semen xv BBC Go to.next question
—General Prowslons for Air Control Eq ens and Prmwaon d fmngmns
Aathnxv CS -m
5 oxstilemndenu in only Iasi
tea; 5..ri.+wbka red pm:rwa elR.p aHw2,smLwXYt,5uF,mlonvBie
eadmnxvll.gs ptureand Monitor..for.orapTanksMedwithAir Pdlmmnamrd Emdpment
40 CRI.Part..Subpart e .lathe°m+dmaddnom.Vassals
1.Is theIndivfolual Besad mna./atetp,u eregoto.5jcA,? .+w)r4.BBwp
2,Dos mTh.lonowing exemption In 30.111bIdINP Yes Storage rank b 00,auhlera xsps 5o,
a.Dom Ma vessel hos s capacity les m'1^l0 BBL)used sate stored,processed,or treated p o<mmdy transfer'os defined 0,30.1110
A.Was.condensate swage tank convincted. homm,,u medium b=2eelMions 400CFR,50 .ie petroleum.
10142 HA
5.Does the storage vessel store s'volatile tlla NOW'.defined In 60111I, NA
B,pee hefollowinr dlnw.lm.mpn.ns: HA
rho aaenvagdmmtanyon..rt a.Is .sel pressure vesselsaltrdcoopes.m wcand tw,B kpar29.7 d1Vith land wuA, ANBsmm a.atss than 3.lso.l(60.110lp;or
Thedayn mewdtYB ymtmrFanerwwlte 151 0,'I"950 BB4antlstorm a Yg,adwltha mullmumtruevap.rpreaure°less than 3s You lan.11ob1611i;.r NA
?.o0, rimy,capacity h g+rcterthan orega+lt°Tsm'rala BBL)bm leas dunssxm'raPa Bpd and aeaaAywdwnha coalmumuo.r.pormessw.'Iastn+nxsakpal6O.11oblbll? NNA
A
ions control a.-Me d.micn capocIty Is greater than or equal.152 m m'1'es0BBQN stoma lquldwm a maemum truevawr pressure greater Mon orwua to 3.3 NPa can as than 5,IAPatw f
L The lto75he x472 BBy but requirements:
131 m'1"B5e BBL]and norm alq,rld with a maximum trve vapor possum gaterMon or aqua to13.0 butlms than 2TSNPa? xA f
POCRF Part so,subN.rf2000/0000.,ANNard.of ParrInmana.far Crude Orland Net lA.s Para..,Trammlelon and dadbmmn
I.h this aonde,s+tesmmgevesse'located at hdllty in.onshore dl and,utuni gas poductronse.menh natural gas proe.umg segment ernatunl gas transmission and nomp segment d the Industry, d tn..w,.ecatgoryen mepMectsummamzM1m.
mnaen+atestoragevessel constructed,reeenstruned,or modlfiea I.derInittons e0 CFR,30,x1 between august 23,x013 am September.,2055} snb,Ns.0000-e.totho neat guetl.n.c.ndnuetlekermlmdonN NSP5000oa appdmdnry.
3.Was thn condensate stongeveseg+omAvetd,reconstructed,or modlflea[zeedellnitmns 40 CfA,30,21 vfte.rs.ptember le,20137
4.Are potential VOC emissions' xlmnl ster+geva5er greater thane,equal to 0 tons per Yeah srag.ranx rsnm suyea xsps0ooa.
5.Does ais condenoote storage,.sel meet...Rion of.slaragevesmi.'pv60,30/605430, HA
6.4 tile gw wait mquke..forstorageressels In aO CFR Pan3usobwrt W w.BCIRPart 635Wpart HH? NA
No f a alamgevassel Is previously determined to be safeette N3P5 00/0000a doom missions tho aboveGmns par VCC en. 0, m.In tydatarmlnation a.,It should ram. to xsps 00 00/0 pr
5ospR
3552)/50.43RS.Ielk ca
l manna Voc.ml.+,er.drop below StorewrVearl
40 st Part pr...a Facilities
1.Is the s tank located an oil and natural ga allry that el.r Me idlowng criteria, Lr.. Ia tints.You have indlmtd thesou,a. fay g nine project sum rysneet.
fa
cility y processes, dm pg or storm hyrrearba Iquds'153fT5op)127Lo
AAANNtytlmt promses,aperads or storm natural gas priortetlwpdnt at which natural gas etmtkrutarsi aas nransmmren atd garage some mtegoryvh detive.d Loa nul and us.;153.2301.11311?
nk located at a facilltythat s major' s? K o i'PraracaPank.net aaPaat MKT.Thereare no MAR I.repuresnemshrtankx al area sources
3,Does tank meet...Ion it.aeh.B en of"domge vessel.In 63.7617
a. enk meet the aui vessel with the potential sl? N'AINT.0
s s nk ubkn Part5o,iWwrtxberzubpan 0000? HA
4527 rd Standards
453,2
453,na Rmnmkewlrn¢
•
RA,raviaw Is required If Regulation,does not opplyAND il.a•nicts lathe namomMment ar.a.lit.tank mama both eirterrarthap marrow PACTragurranranta.
•
Disclaimer
beilyd certainaarvueme.wine Crean AV Aut ifa implemenlMg regulaliona,acrd Ai OualilY ConlydLormrvis,wr regu!NNANN.tits Oazurre I a rid
a N..
and ilea analysis pyy to parti ztlualro ularn.3ed upon lnelrldmdual/acts anderwnatances.This Mcumenfdnes nal change«sulssId ufe/u any laam
Yothe-kgay i meant ands not legally lw enceable In even NAN.con..bellveNn I.language dN W...f and 2hW...W...of the Clean AA'A riling
regulations. kr Ciralta Con.,Goirmissionmplabons,dle...go of ihesaure deeg IN al coop.)Tim use Al nunmanda I g Itl
Intended lAd�crba APCO II' I s mmanAalianz. aria Isrrtinobgyeuh grsryoemallsuAa+d of asetl I nlmlling req Is undaNe terms of the Ckan Ak Aci
,nn p, onWl Commissionreg r0, bulthe document.es nal...sir legacy biMbr
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 7/9/2020
Plant AIRS ID A0B2 Ozone Status Non-Attainment
Facility Name Bath-Schmier 32 Sec HZ
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS ID VOC HAPs VOC HAPs
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 00 0.0 0.0 00 0.0 0.0 0.0 0.0 00 0.0 0.0 0.0 0.0 0.0 0.0 0.0 00 New Facility-No Previous Total
•
011 131110 _ 0.0 , • 00111 pc intls irrelevant'9(11090110ss as veced•by it
- . have already boen petmittedand 0056104 Under
„'. ..
F: point's 949-010&91 bobby.
2.TUi2 y0int vill bob
XA Eleven(11)0.75 MMBtu/hr Burners 0.3 0,3 0.0 3,9 0.1 3.3 0.0 0.3 0.3 0.0 3.9 0.1 3.3 0.0 Insignificant Source
XA Fugitives 0.3 0.0 0.3 0.0 Insignificant Source
XA Produced water storage vessels 0.3 0.1 0.3 0.1 Insignificant Source
XA Sandtrap drain tank 0.6 0.0 0.6 0.0 Insignificant Source
FACILITY TOTAL 1.5 1.5 0.0 0.0 162.4 333.7 0.3 201.8 11.9 1.5 1.5 0.0 0.0 20.3 36.0 0.3 35.7 3.4 VOC:Syn Minor(PSD,NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO:Syn Minor(OP)
HAPS:True Minor
HH:Area source-no affected sources
7777:Area source
Permitted Facility Total 1.2 1.2 0.0 0.0 158.5 332.6 0 0 198.5 11.8 1.2 1.2 00 0.0 16.4 34.9 0 0 324 3.3 Excludes units exempt from permits/APENs
_(A)Change in Permitted Emissions 1.2 1.2 00 0.0 16.4 34.9 0.0 32.4
Modeling not required based on A change in
emissions.Pubcom is required b/c new syn minor
limits are being established and the change in VOC
emissions is greater than 25 tpy.
Total VOC Facility Emissions(point and fugitive) 36.2 Facility is eligible for GP02 because<90 tpy(CO)
and<45 tpy(NOx and VOC)
(A)Change in Total Permitted VOC emissions(point and fugitive) 34.9 Project emissions greater than 25 tpy VOC.
Note 1
Note 2
Page I cif 2 Printed 7/23/2020
001.06.450 DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
ART POLLUTION DIVISION
FACILITY(EMISSION S0I04MAI4T-HAYe
Company Name PDC Energy,Inc.
County AIRS ID 123
Plant AIRS ID A0H2
Facility Neale Rath-5chmier 32 Sec HZ
Emissions-uncontrolled(lbs per year
POINT I PERMIT resorption Formaldehyde Acetaldehyde Acreldn Benzene Toluene Ethylbeezene Xylenes rr-Heeere Me0H 224 IMP H2S I9TAL pd
Previous FACILITY TOTAL 0 0 0 0 0 8 0 0 0 0 0 0 0.0
001 20WE0107 Eleven(11)538 bbl fixed roof condensate 894 1155 20 548 8481 27 5.6
storage vessels _
002 GPO] Hydrocarbon Loadout 119.9 1040.7 0.6
Tortes 003 GP02 SI RICE GM Vortex 5.7L,4SRB,87 HP 193 181 171 102 198 01
(site rated),SN:IOCHMM503090048
004 0302 SI RICE GMVortec 5.7L,4NRB,87 HP 133 181 17.1 102 198 0.1
(site rated),SN:10CHMM503060080
005 GP02 SI RICE Caterpillar G3306NA,4SRB,137 768.9 313 2:7.3 17" 343 0.4
HP(site rated).SN:06X07397
006 GP02 SI RICE Caterpillar G3306NA,4SRB,137 768.9 313 295 177 343 04
HP(site rated),SN:R6002016
007 GP02 SI RICE Caterpillar G3306NA,4080,137 768.9 3'13 295 1;7 343 0.4
HP(she rated),SN:R6S04465
008 GP02 SI RICE Caterpillar G3306NA,45R B,137 768.9 313 295 1';0 343 04
HP(site rated),SN:96003836
009 GP02 SI RICE PSI 11.1L,4SRB,302 HP,SN: 431.5 587 554 333 644 0.3
ERIOH404071
010 GP02 SI RICE PSI 14.6L,43RD,459 HP,SN: 744.2 1013 95.5 374 :11 I 0.6
F22OG501863
011 ,GP-10r. __ ...-.. - -..
012 20WE0601 Natural gas flaring from one(1)surge 447 578 10 274 4241 13 2.8
vessel during VRU downtime,
XA Eleven(11)0.75 MMBtuihr Burners 0.0
XA Fugitives 108 106 105 106 124 0.0
XA Produced water storage vessels 464 415 1 91 246 0.1
XA Sandlrep drain tank 6 e _ 318 0.0
TOTALl(lpv) 2.3 0.2 0.2 0.9 _ 0.9 0.0 0.4 4.9 0.2 0.0 0.0 0.0 119
Total Reportable c all HAPs where uncontrolled emissions>de minimus values
Red Text uncontrolled dr:Temps•de ntm,mus
Emissions with controls(lbs per year)
POINT'PERMIT IOescdpllon Formaldehyde Awramenyde Acroleln eeraene Toluene Ethylbenasse Xylenes n-Hexane Me0H 224 IMP H2S 76TAL dog
Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 ' 0.0
001 20WE0107 Eleven(11)538 bbl freed roof condensate 45 58 r 28 424 2 0.3
storage vessels
002 GP07 Hydrocarbon Loadcut 5 52 0.0
003 GP02 SI RICE GM Vortec 5.7L,45R8,8]HP 131 lo 171 try: 195 01
(site rated),5N:10CHMM503090048
004 GP02 SI RICE GMVortec 5.7L,4SRB,87 HP 133 13I Ill 102 198 0.1
(site rated),SN:10CHMM503060080
005 GP02 SI RICE Caterpillar G3306NA,4SRB,137 768.9 313 295 17', 343 04
HP(site rated),SN:06507397
006 0302 SI RICE Caterpillar O3306NA,4SRB,137 768.9 313 295 177 343 04
HP(site rated),SN:R6502616
007 0PO2 SI RICE Caterpillar G3306NA,4SRB,137 768.9 313 295 177 34'3 ' 04
HP(site rated),SN:R5904405
008 GP02 SI RICE Caterpillar O3306NA,4SRB,137 768.9 313 29.5 177 343 0.4
HP(site rated),SN:06X03836
1199 9392 SI RICE PSI 11.1L,4SRB,302 HP,SN: 431.5 56.7 55.4 333 644 03
EEIOH404971
010 9702 SI RICE PSI 14.6L,45RB,459 HP,SN: 744.2. 101,3 910.5 574 1111 0.6
0ZZ00501863 •
Ott Ge1O'... "i. __ _ _ _.
012 2dWE0601 Natural gas flaring from one(1)surge 23 29 1 14 212 0.1
vessel during VRU downtime.
XA Eleven(111079 MMBluihr Burners - 0.0
XA FugEOves _ _ 108 10.8 105 100 12,4 0.0
XA Produced water storage vessels _ 454 415 1 91 24.6 0.1
XA Sandirap drain tank 68 318 0.0
TOTAL(lpv) 2.3 0.2 0.2 0.2 0.1 0.0 0.0 0.4 0.2 0.0 0.0 0.0 3.4
2 1230,0112 • 2/23/2020
Colorado Mr Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Harrison Slaughter
Package#: 433148
Received Date: 7/6/2020
Review Start Date: 7/8/2020
Section 01-Facility Information
Company Name: PDC Energy,Inc. Quadrant Section Township Range
County AIRS ID: 123 NWSW 32 5N -' 64
Plant AIRS ID: A082
Facility Name: Bath-Schmier 32 Sec HZ 7,
Physical
Address/Location: ^lY:id
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment'.Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? - Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
leave Blank-For Division Use Only
AIRS Point# Permit#
(Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering
APCD has already Emissions Source Type Equipment Name Control? APCD has already # Required? Action Remarks
assigned) assigned)
Permit Initial
012 Separator Venting Surge Vessel Yes 20WE0601 1 Yes Issuance
Section 03-Description of Project
PDC Energy,Inc.(PDC)is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non-
attainment area.With this application,the operator is requesting permit coverage for a surge vessel,condensate storage vessels,hydrocarbon liquid loadout
and engines.The hydrocarbon liquid loadout and engines are requesting general permit coverage.This analysis only evaluates the surge vessel.
This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section ILB.3.a.).Additionally,
the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy(CO AQCC Regulation
3,Part B,Section li.D.2.a.).
Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements,and the change in VOC
emissions as a result of this project is greater than 25 tpy.
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requiremer
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? ':Yes
If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) OOOOO ❑
Title V Operating Permits(OP) ❑ (] OE ❑ OOO
Non-Attainment New Source Review(NANSR) ❑' O
Is this stationary source a major source? No
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits(OP) OOOO ❑ OOO
Non-Attainment New Source Review(NANSR) ❑ ❑
•
Separator/eating Emissions inventory
Section U1-Administrative Information
'Facility AIRS ID: 123 A0B2 012
County Plant Po i
Section 02-Equipment Description Details
Detailed Emissions Unt Description: Naturalgas flaring from one(1) ge vesseld 6tg pne recoveryunit MUidovrnbmc. T P ;ei 4q vx--�** per.
Emss an Control Dev ce Oescr pt on _ ��.
414
Requested Overall VOC&HAP Control Efficiency Sd: 95 °
Limited Process Parameter (uIdTh✓tom rpuL ;_ �. ,
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Separator
Actual Throughput= 80078 Barrels(bbl)per year
Requested Permit Limit Throughput '96,093 Barrels(bbl)per year Requested Monthly Throughput= Barrels(boll permonth
Potential to Emit(PTE)Throughput= Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)for Air Pollution Central
Separator Gas Heating Value: .2461.3 Btu/scf
Volume of waste gas emitted per BBL
of liquids throughput 22.8 scf/bbl
Control Device
Pilot Fuel Use Rate( scfh MMscf/yr
Pilot Fuel Gas Heating Value: Btu/scf
Section 04-Emissions Factors&Methodologies
Description
Liquid produced by the eleven(U)wells flows to eleven(11)inlet three-phase:separators.The liquid from the three-phase separators is then routed to asurge vessel which further separates thefluid phase.The
hydrocarbon liquid from the surge vessel then flows to a third part(pipeline to be sold via Leasa Automatic Custody Transfer(LACT)unit During 000 downtime,surge vessel emissions are routed to the storage vessel
vapor manifold and controlled with the condensate storage vessel emissions-Emission federates this source warecalculated using site specific pressurized liquid sample obtained from the outlet of the inletthree.phase.
separator for the.Bath-Schmier 110 well on 11/08/2019 In conjunction with ProMax.The sample temperature and pressure are 133'°F and 25.3 pslg respectively.As discussed in Section 08,the emission factors used for
this source reflectthe emission factors developed for the condensate storage vessels and constitute a conservative estimate of emissions.Values from the ProMax simulation are shown In thetable below.
ProMax Flow Rate 240,233.00 bbl/year
Total Waste Gas Rate
Pollutant Flash Gas(lb/hr) W&B Gas(lb/hr) Source
(16/hr)
VOC 36.40311942 18.45368935 .ProMax
Benzene 0.0961978 0.0313701 _ ProMax
Toluene 0.122277 0.0425042 ProMax
Ethylbenzene 0.00204405 0.009780856 ProMax
Xylenes 0.0521374 0.0260604 ProMax:
n-Hexane - 0.813323 0.396339 ..... :.ProMax
2,2,4-TMP 0.00253561 0.00120276 ProMax
Emission Factors Separator Venting
Uncontrolled Controlled
(16/1.1) (16/661) Emission Factor Source
Pollutant
(Liquid Throughput) (Liquid Throughput)
VOC __. ProMax
Benzene _ Je0Max
Toluene _-_ — 'ROM
Ethylbenzene proM>x
Xylene _ 13eMa
n-Hexane .. .ProMax
224 TMP "_— _ ."VtaM .
Primary Control Device
Uncontrolled Uncontrolled
Pollutant (lb/MMBtaI Ib/bbl Emission Factor Source
(Waste Heat
Co
mbusted) (Gas Throughput)
PM10 0.0075 -"43.42Tabin1.42(PMSGjPA1:25)
PM2.5 ,0.0675 _ `[Ir-427 hlo1 2(PMSO/PM.Z5(
500 0,0006 'AP-4203b101.4-2(5ox)
NO. 0.1330: y4nZ3 e6mis`ulons Gu i32(NOx)."
CO 0.2755 _ TNRCC Clara Erofislens Guidaqa('(Co)
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MitrBtu) lb/MMscf Emission Factor Source
(Waste Heat
Combusted) (Pilot Gas Throughput)
PM10
PM2.5
SOx
NOx
VOC
Section OS.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) (tans/year) (tans/year) (Ibs/month)
PM10 .s..t :., _
PM2.5 .. .__.
505 .. ".
500 .. _._.
VOC _._ .. ...
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) Il be/year) Ilbs/yearl Ilbs/yearl Ps/year)
Benzene ==
Toluene .._. _..
Ethylbenzene _ _._ s
pylene
n-Hexane :..
224 TMP ._ -
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Section 56-Reeulatory Summary Analysis
Regulation 3,parts A,B ....
Regulation 7,Part S,Section 11.B,F
Regulation 7,Part 0,Section II.B.2.e
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Roclrements
Cd'S On"._P"4 t anti F t
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h K7.°' r,. <.., . ..0 ,. z <..e -.�is i
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,iris'..5-'M ➢%-':wU"rB ,.:',,..n-'r.,,3,1 .e. ''sr�-.
Using liquid Throughput to Monitor Compliance
Does the company use site specific emission factors based on a pressurized Ilquld sample(Sampled upstream of the
equipment covered under this AIRS ID)and process simulation to estimate emissions?
This sample should have been 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.
R no,the permit will contain an"Initial Compliance"testing requirement to collect a site-specific liquid sample and conduct an emission factor
analysis to demonstrate that the emission factors are less than or equal tothe emissions factors established with the application.
Does the company request a control device efficiency greaterthan 95%for a flare or combustion device?
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysts Notes
1.The sitespecifesempleusedto establish emissionsfactors forthissource was obtained within year of the appllationThesample wasobtainedfrom the Bath-SchmierllN well on I1/08/2019.This well s one of the eleven new wells
drilled at tlisfecility.Addltionellythesample was obtained afterelithe wells at this facility began production.Asa result,the permit will not require initialtesting in order to obtain sitespecificsample.it should be notedthat the sample
ish ncludessample probetemperature and pressure In conjunction w gauge pressureand temperature.According to lab infonmat on,the sample probe temperatureend pressure are obtained using lab equipment during the sampling
p ocess.These'v lues er expeaedto be more accurate compared to the gauge values and are acceptable for use in the simulationto establish site specific emission factors.
2.Please refeMncethe cond¢nsateworage Vessell APEN submitted on 12/02/19 fora list of the eleven neW weilsat this facil ty The wells associated with this tank battery were fractured in August 2019 and began production in September
2019.Ten of the eleven wellsat this facility produce from the Niobraraformation.The eleventh well producesfrom the Cariile,Codell and Fort Hays formations..
3.The permit will not contain initial or per oil copacfy testing fortheenciosed oombustorts)because the 0&M plan approved forths source requires weekly visible emissions observationsof the enclosednambustor(s).
4.Emssonfaaors for ethylbenzene and 2,2,4-TMP will not be included in the permit because are below APEN reporting thresholds(i.e.n250 lb/year).
S.During VRU downtime,the surge vessel Is controlled by thesame enclosed combustors used to control storage vessel emissions.According to engineering guldance,thepilot light emissions are grouped with the highest emitting source
controlled by the common control device.In this case,the storage vessels are the highest emitting source.As'a result pilot light emissions are accounted for wRhthe storagevessels(20WE0107)and not this analysis.
6.According.:engineerguidance,the total combustion emissions(i.e.NOx and CO)from all the sources controlled bye common control device should be added together for evaluation against APEN reporting thresholds.In this case,NOx
and CO emissions from the surge vessel are below APEN thresholds,However,total NOx end CO emissions from all the sources controlled by the enclosed combustors(i.e.st age vessels and urgevessel)are above APEN reporting
thresholds,As:a.result all the sources controlled by the common control device will.lnclude limits on both NOx and CO emissions,
7.In orderto calculate surge vessel emissions,the operator Is usingtheemissionfactors esteblishedfo the condensatesttiragevessels.These emission factors were deemedaaeptableand conservativeforthe following reasons:(I)The
operator indicatedthat the surgevessel is not usedto store condensatepriorto sending the liquidto the LACT.This is supported by the information that the condensateis routed directly s fn the eventthatthe LAC?is
not available.As a result,the emissioncfromthe sulgevessel do nonincludeworking and bnoethtngemissiomjn actual operadon.The emission factors developed forttieandensate storage vessels do inctudeworking and breathing
em
issions.()Further,the operator indicated that the surge vessel usually operates between 4-6 pslg,whereasthe storageyessee operate at essentially ambient pressure(0 psig).The PrcMex simulation mod lsflash emissioristtiatoavr
from 37.8 psis to 12.5 psia.Since the surge vessel operates at a higher pressure,theflash emissions are likely less than what...modeled by the ProMaxsimuletion forthcstoragevessels
8.Accordingtothe apps atfon,°The hydrocarbon:liquid flows to a surge vessel,which furtherseparatesthefluid phase.The hydrocarbon l quidthen flows to a third party pipellneto beseld via e Lease Automat cCustody Transfer(LACE)
unit.At times when the surgevess l is not operational,thecondersateflowsto eleven(11)538 bbl condensate storagevessele.Thetank vapors are sent to the enclosed combustors."Based onthefadiity design,emissions occur when the
hydrocarbon liquid is sentto the storagevessels rather than the surgevessel and whenthesurge vessel VRU a down.It was determinedthatthestorage vessels and surge vessel do not meet the APEN grouping requirements and must be
permlttedseperately.This determination was made fora couple masons.First of which istl?atthe surgevesseband storagevessels are two distinct emitting unitsthat have different control scenarios and distinctthroughputvalues.Further,
the regulatory applicablityforthestorage vessels distinctly different from that of the surgevessel.The surge vessel is not classified or defined as astorag vessel endwouldtherefote not b regulated as such under NSPS Kb,MPS
0000/0000a or Regulatlon7:instead,the surgevessel would be classified as aseperetorfor Regulation7reguirements.Ths permit only uddressesthe throughput routed to the surgevess l and the resuhmgemssios5nceemissons
only result during VRU downtime,the permit will contains VRU downtimetracking condition.
9.The operator indicated that rheir5CADA system disinctlymeasuresthevolume of hydrocarbon liquid sentto eitherth surge:vessel or the storagevessels.As a result,the hydrocarbon liquidthroughputforthe surge vessel and storage
vessels can be determined independently and accurately.
10.Since the surgevessel(separator)emisslunsareless than l00tpythe operator is not required to use a flow meter and gas throughput for ongoing compliance demonstrations.Furtherthe facility isdesignedsuch that the emissions
fromthe surge vessel are routed.the condensates.rage vessel vapor manifold end...controlled In conjunction with the condensate storagevessel emissions.Based`onthefacflity design,retroactive Installation of a flow meter isnot
feasible and would not provide a means of differentiatingstoage vessel missions front surge vessel emissions.Additiunely,the operator is being overly conservative n calculating emssions nether are using the emissionfactors
developed forthe storage vessels.Finally,theoperetor already has a means of accurately quantifying the liquidthroughpraforthesurge vessel.Based:on these reasons,:Owas determinedthat liquid throughput was a viable optionfor
demonstrating ongoing compliance.
11.-The operator was provided with a draft permitand APEN redline to review prior to public comment.The operator reviewed both cocci ants and expressed they had one comment on the daft permit.The eamment provided by the
operator and_the Division response a as follows:I)Comment,'I've reviewed both of the draft permits and APENredllnes.5imilartoWilmothand Thistle Down,the only comment on draft permit 20WE0601:is in regards to the:notice of
startup condition.I have attached a receipt of the eNOSsubmlttal for your reference.Can this permit condition please be removed?"'Response:Thank you for providing a copy of the completed eN05.Since a complete 0500 has been
submitted,theN05 condition will be removed from the permit as requested.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
AIRS Point k Process X SCC Code Pollutant Uncontrolled Emissions Factor Control% links
012 01 is C PM10
PM2.5 .._
50x
NOx
VOC
CO .>., .. ..,.
Benz
ene
Toluene
Ethylbenzene
Rylene
n-Hexane
224TMP
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Separator Venting Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
.Sa,RP<t.15 m ti',@ tto,l•?ttae1nt1,5,1 A+ew
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. Are total facility uncontrolled V0C emissions greater than 5 TPY,N0x greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Pert B,Section 11,8.4)?
kg.:,act,vslcateu that soup a tc w n,e faun Att mm<vrt Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section 11.0.1.x)? Yes Sconce Requires an APEN.Go to the next question
2. Are total facility uncontrolled V0C emissions from the greater than 2TPY,N0x greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.5.2)? Yes-r .:..Source Requires a permit
I4at,eca cequ,rr's
Colorado Regulation 7,Part!),Section II
1. Was the well newly constructed,hydraulically fractured,orrecompleted on or after August 1,2014? IYes4xx,7ISource is subject,go to next question
Section 11.8.2—r General Provisions for Air Pollution ControlEquipment Used to Comply with Section II
Section II.F-Control of emissions from well production facilities
Alternative Emissions Control(Optional Section)
a. Is this separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? 'Nb
ibr,oui,ui,.1evKr for also,sm.a,at,.r is cot Subp:,t,u P.,;(11,...11 a.Y..,..,,,e x.0,,n L.
Section II.B.2.e—Alternative emissions control equipment
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is
not a rule or regulation,and the analysis it contains may not apply tea particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law,
regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its
implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should,"
and"can,"is intended to describe APCD Interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of
the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself
CDPHE Condensate Storage Tank(s) APEN
Form APCD-205
CO ! 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.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.colorado.Qov/pacific/cdphe/air-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 reportage 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: 01 AIRS ID Number: I2 / ji.f
[Leave blank unless APCD has already assigned a permit it and AIRS ID]
Section 1 -Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Bath-Schmier 32 Sec HZ
Site Location: Site Location
NWSW Sec 32 T5N R64W county: Weld
NAICS or SIC Code: 1311
Mailing Address:
(include zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address2: Jack.Starr@pdce.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes wilt require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address,pfovided.
4?-21(1 v)
COtot*so
Form APCD-205 Condensate Storage Tankisi APEN Revision 7/2018 1 1 ,
Permit Number: L LAX eirit AIRS ID Number: 113 1 /
(leave blank unless APCD has already assigned a permit I and AIRS ID)
Section 2- Requested Action
❑ NEW permit OR newly-reported emission source
Q 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 S312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment O Change company name3
❑ Change permit limit O Transfer of ownership's 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&Notes: Initial permit request for condensate storage tanks at a new facility
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted.
Section 3 -General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources,operation began on: 09/03/2019
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: I] Exploration&Production(EEtP)site O Midstream or Downstream(non E&P)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 a 500 bbl/day? ❑ Yes O No
If"yes", identify the stock tank gas-to-oil ratio: 0.004065 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) O Yes ❑ No
805 series rules?If so,submit Form APCD-105.
Are you requesting a 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual Q Yes ❑ No
emissions a 6 ton/yr(per storage tank)?
caioIxoo
Form APCD-2O5 Condensate Storage Tank(s)APEN - Revision 7/2018 2 I w';,�"
Permit Number: . tc--O1' ° , AIRS ID Number: I / 1
[Leave blank unless APCD has already ass)gned a permit a and AIRS ID)
•
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
( Condensate Throughput: 240,334 Notics - 228.278• fit.1%eal.o
From what year is the actual annual amount? Projected
Average API gravity of sales oil: 50.2 degrees RVP of sates oil: 7.8
Tank design: D Fixed roof 0 Internal floating roof 0 External floating roof
Storage if of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TK-1 11 5,918 10/218 9/2019
Wells Serviced by this Storage Tank or Tank Battery6(EBP Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 -45072 Bath-Schmier 1C D
05 • 123 •45077 Bath-Schmier 2N D
05 • 123 -45078 Bath-Schmier 3N D
05 -123 •45074 Bath-Schmier 4N 0
05 -123 -45067 Bath-Schmier 5N D
5 Requested values wilt become permit limitations.Requested limit(s)should consider future growth.
6 The EEO:,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
(Latitude/Longitude or UTM)
40.35228/-104.58138
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)
Upward O Downward O Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
o Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
pp COIOl4DO
Form APCD-2O5 Condensate Storage Tank(s)APEN • Revision 7/2018 3 I L '"`"
WAAVI,44itt> •Pt,,r V aPt* + .
"IYit14111 t67
Permit Number: AIRS ID Number: /401,1, c,
[Leave blank unless APCD has already assigned a permit rr 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:
Vapor Size: Make/Model:
O Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed(emissions vented):
Pollutants Controlled: VOC & HAPs
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model:11 x Cimarron 48",1 x Cimarron 60"
Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,461.35 Btu/scf
Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.0,'S 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)? 25.3 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
kIDS
Air CO/ : O
Form APCD 205 Condensate Storage Tank(sI APEN - Revision 7-2018 4 I €]' OOD
Permit Number: -Loupe M
.} AIRS ID Number: It., /Acv_ / 00 I
(Leave blank unless APCD has already assigned a permit u 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
(%reduction in emissions)
VOC Enclosed Combustor 95%
NOx
CO
HAPs Enclosed Combustor D5%
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Emission Factor Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions Emissions Emissions
Mfg.etc) (Tons/year) - (Tons/year) _ (Tons/year) (Tons/year)
VOC l.cui3j�.I i� '', h.yj 1lu{).+°1 CS.o1 lqI.tL 9.bi-
NOx Q,I*g,0.Vi.S ik4,..,., 'race/AP-qt. , 0.r6 G•SSLI 1.0 t.C7
Co u,'1.ssIo•3l "f m^+vt� 7cc 1Ar'-gL 1.%4 1.Et,'-1 t.t5 4 2..IS
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissionsa
Number Basis Mfg.etc) (Pounds/year) (Pounds/year)
Benzene 71432 0.0047 • Ib/bbl ProMax 1KS 31.•5
Toluene 108883 0.0060• Ib/bbl ProMax €ltd.•% '-t8.1
Ethylbenzene 100414 1.05E-04• lb/bbl ProMax 1‘.."4 l t ) 0.9,(9w)
Xylene 1330207 0.0029• IbIbbl ProMax tist,..} tt.8
n-Hexane 110543 0.0441• lb/bbl ProMax ;c:41-.S 3s3.4
2,2,4- 540841 1.36E-04 Ib/bbl ProMax z,l.�(,..,) I.�I;r�•k)
Trimethylpentane ylp -
5 Requested values will 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.
7 kia.�.q• ./ vradr—t .-p (olkimk,.
Ft bS
COIO9&DO
Form APCD-2O5 Condensate Storage Tank(s)APEN - Revision 7/2018 5 I ,Q� ,
Permit Number: lJ AIRS ID Number: i- O2si --/ 1
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 9-Applicant Certification
I hereby certify that alt information contained herein and information submitted with this application is complete,
true,and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Sig re of Legally Authorized Person(not a vendor or consultant) Dat
Jack Starr Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term,or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements.
Send this form along with$191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 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.colorado.Qov/cdphe/aped
COLo�400
Form APCD-2O5 Condensate Storage Tankisl APEN- Revision 7/2018 6 I A. . ,
E&P Storage Tank Air Pollutant Emissions Notice(APEN) Addendum Form'
Company Name: PDC Energy,Inc.
Source Name: Bath-Schmier 32 Sec HZ
Emissions Source AIRS ID2: N/A/t , /Pr 7..4 0 tJ 1
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05- 123-45076 Bath-Schmier 6N
05.123.45081 Bath-Schmier 7N IYt
05- 123.45084 Bath-Schmier 8N ►.1
05.123-45085 Bath-Schmier 9N ►1
05- 123-45083 Bath-Schauer 10N �1
05- 123-45082 Bath Schmier 11N ►�1
- - ❑
- ❑
- _ ❑
- - ❑
O
- - ❑
171
- - ❑
- - ❑
- - ❑
- ❑
- ❑
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-t Addendum
Received 07/06/2020.
MR:� Gas t1utantVen�ting missionAPEN - Form APCD-211
Notice (APEN) and
CDPHE 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 gas venting only. Gas venting includes emissions from gas/liquid separators, well head
casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this
category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid
loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the
specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the
Air Pollution Control Division (APCD)website.
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 20WE0601 AIRS ID Number: 123 /A0B2 / 012
[Leave blank unless APCD has already assigned a permit and APS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Bath-Schmier 32 Sec HZ
Site Location
Site Location: NWSW Sec 32 T5N R64W Weld
County:
NAICS or SIC Code: 1311
Mailing Address: 1775 Sherman Street, Suite 3000
(Include Zip Code)
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.
COLORADO
Form APCD-211 Gas Venting APEN - Revision 12/2019 1 'x "�"
Permit Number: 20WE0601 AIRS ID Number: 123 /AOB2/ 012
[Leave blank unless APCD has already assigned a permit 4-and AIRS ID;
Section 2 - Requested Action
❑� NEW permit OR newly-reported emission source
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3 ❑ Add point to existing permit
❑ Change permit limit ❑ Transfer of ownership4 0 Other(describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes: APEN submittal for emissions associated with surge vessel vapor recovery unit(VRU)downtime.
Emissions calculated using the condensate storage tank ProMax simulation and emission factors
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Surge vessel VRU downtime emissions
Company equipment Identification No. (optional): Surge Vessel
For existing sources, operation began on: 9/3/2019
For new, modified, or reconstructed sources, the projected start-up date is:
El Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below:
Normal Hours of Source Operation: hours/day days/week weeks/year
Will this equipment be operated in any NAAQS
❑✓ Yes ❑ No
nonattainment area?
Is this equipment located at a stationary source that is
❑ Yes ❑✓ No
considered a Major Source of(HAP) Emissions?
Is this equipment subject to Colorado Regulation No. 7,
p Yes 0 No
Section XVII.G?
COLORADO
Form APCD-211 - Gas Venting APEN - Revision 12/2019 2 ; ': � ,
Permit Number: 20WE0601 AIRS ID Number: 123 iA0B2/ 012
[Leave blank unless APCD has already assigned a permit.=and AIRS ID]
Section 4 - Process Equipment Information
❑✓ Gas/Liquid Separator
❑ Well Head Casing
❑ Pneumatic Pump
Make: Model: Serial#: Capacity: gal/min
❑ Compressor Rod Packing
Make: Model: #of Pistons: Leak Rate: Scf/hr/pist
❑ Blowdown Events
#of Events/year: Volume per event: MMscf/event
❑ Other
Description:
If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas
Venting as a process parameter.
Are requested uncontrolled VOC emissions greater than 100 tpy? ❑r Yes ❑ No
Vent Gas 2 461 BTU/SCF
Gas Venting Heating Value: ,
Process Parameters5: Requested: 2.1 93 MMSCF/year Actual: 1.828 MMSCF/year
-OR-
Liquid Throughput
Process Parameters5: Requested: 96093 bbl/year Actual: 80,078 bbl/year
Molecular Weight: 43.9771
VOC (Weight%) 75.62
Benzene (Weight%) 0.18
Vented Gas Toluene (Weight%) 0.23
Properties: Ethylbenzene (Weight%) 0.004
Xylene (Weight%) 0.11
n-Hexane(Weight%) 1.67
2,2,4-Trimethylpentane (Weight%) 0.01
Additional Required Documentation:
❑✓ Attach a representative gas analysis(including BTEX It n-Hexane, temperature, and pressure)
❑ Attach a representative pressurized extended liquids analysis(including BTEX Et n-Hexane, temperature, and
pressure)
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.
COLODO
Form APCD-211 Gas Venting APEN - Revision 12/2019 3 "R A
NUM 6 En�lronmint
Redlines per application. (HDS 07/09/2020)
Permit Number: 20WE0601 AIRS ID Number: 123 iA0B2/ 012
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.35228/-104.58138
❑ 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.
Discharge Height
operator . Temp Flow Rate Velocity
Above Ground Level
Stack ID No, CO (ACFM) (ft/sec)
(Feet)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward O Upward with obstructing raincap
❑ Horizontal ❑ 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):
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Size: Make/Model:
O VRU:
Requested Control Efficiency:
VRU Downtime or Bypassed:
Pollutants Controlled: VOC & HAPs
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model: 11 x Cimarron 48"&1 x Cimarron 60"
❑✓ Combustion Requested Control Efficiency: 95
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,461 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot burner Rating: 0.018 MMBtu/hr
Pollutants Controlled:
Q Other: Description:
Requested Control Efficiency:
ICOtORADO
Form APCD-211 - Gas Venting APEN - Revision 12/2019 4 I I°`° L""`i IfeaAhb Environmrnt
Permit Number: 20WE0601 AIRS ID Number: 1 23 /AOB2/ 012
[Leave blank uniess APCD has already assigned a permit#and AIRS Dj
Section 7 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No
If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (7 of total emissions captured (7 reduction of captured
by control equipment) emissions)
PM
SO.
NO.
CO
VOC Enclosed Combustors 100% 95%
HAPs Enclosed Combustors 100% 95%
Other:
From what year is the following reported actual annual emissions data? Projected
Use the following table to report the criteria pollutant emissions from source:
Emission Factor Actual Annual Emissions Requested Annual Permit
Pollutant Emission Limit(s)5
Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions
Basis
Mfg.,etc,) (tons/year) (tons/year) (tons/year) (tons/year)
PM
SO.
NOx 0.1380 lb/MMBtu TCEQ N/A 0.31(DM) N/A 0.37(DM)
CO 0.2755 lb/MMBtu TCEQ N/A 0.62(DM) N/A 0.74(DM)
VOC 2.0003 lb/bbl ProMax 80.09 4.00 96.11 4.81
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable, and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
•
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria (] Yes ❑ No
pollutants (e.g. HAP - hazardous air pollutant) equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant (HAP) emissions from source:
Chemical Emission Factor Actual Annual,Emissions
Abstract Source Uncontrolled Controlled
Chemical Name Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions
Basis
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.0047 lb/bbl ProMax 372.50 18.62
Toluene 108883 0,0060 lb/bbl ProMax 481.15 24.06
Ethylbenzene 100414 0.0001 lb/bbl ProMax 8.37(DM) 0.42(DM)
Xylene 1330207 0.0029 lb/bbl ProMax 228.34(DM) 11.42(DM)
n-Hexane 110543 0.0441 lb/bbl ProMax 3,533.67 176.68
2,2,4-Trimethylpentane 540841 1.36E-04 lb/bbl ProMax 10.92(DM) 0.55(DM)
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
'@ Form APCD-211 -Gas Venting APEN - Revision 12/2019 5 I '*V.70i=7,=„
Permit Number: 20 E0601 AIRS ID Number: 123 /A0B2 i 012
[Leave Marl unless APCD has a ready assigned a perint P.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.
Sing Lure of Legally Authorized Person(not a vendor or consultant) S SlDate
Jack Starr Senior Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
❑r Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes,may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration
of the five year term,or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$191.13 to: For more information or assistance call:
Colorado Department of Public Health and Environment Small Business Assistance Program
Air Pollution Control Division (303)692-3175
APCD-SS-B1 OR
4300 Cherry Creek Drive South (303)692-3148
Denver,CO 80246-1530
APCD Main Phone Number
Make check payable to: (303)692-3150
Colorado Department of Public Health and Environment
iet.gtCOLORADO
Form APCD-?11 Gas Venting 4-FF - Revisicn 12/2019 6 ! muorror Y;bIn„sseear„
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