HomeMy WebLinkAbout20203735.tiff C.
COLORADO
4 Department of Public
ti CDP"' Health&Environment RECEIVED
DEC 0 7 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
December 2, 2020
Dear Sir or Madam:
On December 3, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
PDC Energy, Inc - Clark 14 Sec HZ; J Clark 14 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
of c'gt -,
4300 Cherry Creek Drive S., Denver,Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I 4 � �� '
ii,) .� o
Jared Polis,Governor I Jill Hunsaker Ryan,MPH, Executive Director t
cC?L(TP),HL(DS/TR),pr,)(SM/ERkH/cO, 2020-3735
12/23/20 12/I5/20
C441 ItMF Air Pollution Control Division
CD Notice of a Proposed Project or Activity Warranting Public
CDPHE
M Comment
Website Title: PDC Energy, Inc - Clark 14 Sec HZ; J Clark 14 Sec HZ - Weld County
Notice Period Begins: December 3, 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: Clark 14 Sec HZ; J Clark 14 Sec HZ
Well Production Facility
NWNE quadrant of Section 14, Township 5N, Range 65W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc wishes to reduce requested permitted
emission by reducing requested condensate throughput. PDC Energy, Inc also wishes to change coverage of
condensate loadout activities from a GP07 to a traditional permit.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• 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 drafts of Construction Permits 19WE0186 and
20WE0755 have been filed with the Weld County Clerk's office. A copy of the draft permits and the
Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-
permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Department of Public
I i `°'' Health bEnvironment
C4 ,.....t., COLORADO
% Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 1 9WE01 86 Issuance: 2
Date issued: XX/XX/XXXX
Issued to: PDC Energy, Inc.
Facility Name: Clark 14 Sec HZ; J Clark 14 Sec HZ
Plant AIRS ID: 123/9F4F
Physical Location: NWNE Quadrant of Section 14, Township 5N, Range 65W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID
TK-1 001 Twenty-Six (26) 538 barrel fixed roof Enclosed Combustors
storage vessels used to store condensate
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-setf-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
Page 1 of 9
4 COLORADO
>41.0 Air Pollution Control Division
Department of Public Health Ft Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NO,t VOC CO Type
TK-1 001 --- 2.3 26.5 4.9 Point
Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant shall not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants shall apply to all permitted
emission units at this facility.
Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on
the previous twelve months' data. The permit holder must calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
6. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility AIRS Control Device Pollutants
Equipment ID Point Controlled
TK-1 001 Enclosed Combustor VOC and HAP
Page 2 of 9
,: COLORADO
4 44441 Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PROCESS LIMITATIONS AND RECORDS
7. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility AIRS Process Process Parameter Annual Limit
Equipment ID Point
01 Condensate Throughput 244,728 barrels
TK-1 001 02 Combustion of pilot 2.6 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
8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
'Part B, Section III.E.) (State only enforceable)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
Page 3 of 9
CCOLORADO
4` Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
12. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%.
If a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to
March 1, 2020. The source must follow the inspection requirements of Regulation Number 7,
Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made
available to the Division upon request. This control requirement must be met within 90 days of
the date that the storage tank commences operation.
13. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission
Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2.
14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Ft MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. All previous versions of this permit are cancelled upon issuance of this permit.
19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
Page 4 of 9
-r,_ ,. COLORADO
1 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
20. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D)
GENERAL TERMS AND CONDITIONS
21. This permit and any 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
Page 5 of 9
0 COLORADO
4 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit,the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Diego Chimendes
Permit Engineer
Permit History
issuance Date Description
Issuance 1 July 8, 2019 Issued to PDC Energy, Inc.
Issuance 2 This Issuance Issued to PDC Energy, Inc. Operator reduced
permitted emissions by reducing requested
condensate throughput.
Page 6 of 9
Cri, COLORADO
tor Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common.Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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 2263 113
Toluene 108883 3013 151
Ethylbenzene 100414 89 4
001 Xylenes 1330207 1115 56
n-Hexane 110543 22627 1131
2,2,4-
540841 61 3
Trimethylpentane
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per
year(lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 1.798x10-2 1.798x10-2 TNRCC and Promax
CO 3.589x10-2 3.589x10-2 TNRCC and Promax
VOC 4.3257 2.1628x10-' Promax Site
specific
Page 7 of 9
ry� COLORADO
AIL
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
71432 Benzene 9.246 x 10-3 4.624 x 10-4 Promax Site
specific
108883 Toluene 1.231 x 10-2 6.155 x 10-4 Promax Site
specific
1330207 Xylene 4.555 x 10-3 2.277 x 10-4 Promax Site
specific
110543 n-Hexane 9.246 x 10-2 4.623 x 10-3 Promax Site
specific
Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific VOC
and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax
simulation. The site specific sample used in the ProMax simulation was obtained from the J Clark 13N well on
02/11/2019. The NOx and CO TNRCC emission factors (0.1380 lb/MMBtu and 0.2755 lb/MMBtu respectively)
were converted to units of lb/bbl using a heat content of 2593.2 Btu/scf, molecular weight of 46.2 lb/lbmole,
a standard molar volume of 379.41 scf/lb-mole, and a VOC mol%of 70.7%.Actual emissions are calculated by
multiplying the emission factors in the table above by the total condensate throughput.
Process 02: Combustion of pilot light
Uncontrolled Emission
CAS # Pollutant Factors Source
lb/MMSCF
N0x 77.2 AP-42 Chapter 13.5
V0C 6.1 AP-42 Chapter 1,4
Table 1.4-2
CO 352.2 AP-42 Chapter 13.5
Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5
NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,136
Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4
emission factor by a heat value of 1,136 Btu/scf. Actual emissions are calculated by multiplying the emission
factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a
constant rate of 15.6 scf/hr.There are a total of nineteen(19)combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 296.4 scf/hr.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN must be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Page 8 of 9
• rT.. COLORADO
4 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, Et n-Hexane. True Minor
Source of CO.
PSD True Minor Source of: CO £t NOx
NANSR Synthetic Minor Source of: VOC Et NOx.
MACT HH Area/Major Source Requirements: Not Applicable
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.ov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A- Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA- Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Diego Chimendes
Package 9: '434903
Received Date: 8/27/2020
Review Start Date: 110/13/2020
Section 01-Facility Information
Company Name: PDC Energy,Inc Quadrant Section Township Range
County AIRS ID: 123 NWNE 14 5N 65
Plant AIRS ID: 9F4F
Facility Name: Clark 14 Sec HZ;}Clark 14 Sec HZ
Physical
Address/Location: NWNE quadrant of Section 14,Township 5N,Range 65W
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment?Oil&Natural Gas Production&Processing
Is this facility located in a NAAQS non-attainment area? Yes
If yes,for what pollutant? Ozone(NOx&VOC)
Section 02-Emissions Units In Permit Application
Leave Blank-For Division Use Only
AIRS Point# Permit#
Emissions (Leave blank unless Issuance Self Cert Engineering
(leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit
001 Storage Tank TK-1 Yes 19WE0186 2 Yes Modification
Section 03-Description of Project
PDC Energy,Inc.(PDC)submitted an application requesting modification of permit 19WE0186.PDC wishes to reduce requested permitted emission by reducing
requested condensate throughput.
This point source is APEN-required because uncontrolled V0C emissions are greater than 1 tpy and uncontrolled emissions of at least one non-criteria pollutant is
greater than 250 tpy.(Regulation 3 Part A Section II.B.3.)Point source is permit-required because uncontrolled facility-wide V0C emissions are greater than 2 tpy.
(Regulation 3 Part B Section 11.0.2.).
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in order to
avoid other requirements.(Regulation 3 Part B Sections III.C.1.d.).
Point source is not subject to ambient air impact analysis.(Regulation 3 Part D Section II.A.44).
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD)
Title V Operating Permits(OP) J J ❑ ❑J
Non-Attainment New Source Review(NANSR) ✓ ✓
Is this stationary source a major source? No
Colorado Air Permitting Project
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) r _
Title V Operating Permits(OP) _ _ ❑ ❑
Non-Attainment New Source Review(NANSR)
f.ge Tank(s)Emissions Inventory
Section 01-Administrative Information
'Facility AIRs ID: 123 9F4F 001.
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid Condensate
Detailed Emissions Unit Twenty-Six(26)538 barrel fixed roof storage vessels used to store condensate.
Description:
Emission Control Device Eighteen(18)Cimarron 48"&one(1)Cimarron 60"enclosed combustors.Description:
Requested Overall VOC&HAP Control Efficiency%: 95.0
x
Limited Process Parameter
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= 203,940.0 Barrels(bbl)per year
Requested Permit LimitThroughput= 244,728.0 Barrels(bbl)per year Requested Monthly Throughput= 20785.1 Barrels(bbl)per month
Potential to Emit(PTE)Condensate Throughput= 244,728.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2593.2 Btu/scf
Volume of waste gas emitted per BBL of liquids scf/bbl
Molecular Weight= 46.2 Ib/Ibmel
VOC mel%= 70.67%
Molar Volume= 379.4 scf/Ibmol
Actual heat content of waste gas routed to combustion device= 26,565.5 MMBTU per year
Requested heat content of waste gas routed to combustion device= 31,878.5 MMBTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= - 31,878.5 MMBTU per year
Control Device
Pilot Fuel Use Rate: 2964;scfh 2.6 MMscf/yr
Pilot Fuel Gas Heating Value: .�.j"°fit 6_Btu/scf 2949.6 MMBTU/yr
Section 04-Emissions Factors&Methodologies
Will this storage tank emit flash emissions? ≥L.
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (Ib/hbp Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 4.3257E+00 2.1628E-01 Site.Specific E.F.(includes flash)
Benzene 9.246E-03 4.623E-04 Site Specific E.F.{includes flash)
Toluene 1.231E-02 6.155E-04 Site Specific EF.(includes flash)
Ethylhenzene 3.636E-04 1.818E-05 Site Specific E.F.{includes flash)
Xylene 4.555E-03 2.277E-04 Site Specific EP.(includes flash)
n-Hexane 9.246E-02 4.623E-03 Site Specific E.F..(includes flash)
224 TMP 2.500E-04: 1.250E-05 Site Specific E.F.(Includes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant )lb/MMBtu) (lb/bbl) Emission Factor Source
(waste heat (Condensate
combusted) Throughput)
PM10 0.0075 9.71E-04 .42Talte1 .§
PM2.5 0.0075 9.71E-04 '"g�y
. f '"- F
SOx 0.0006 7.66E-OS 'S12,7121:',,,-,219,_-1(11'''',_`-
NOx 0.1380 1.798E-02 t i x -"5 V
CO 0.2755 3.589E-02 p;:: ,9,4
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas
Combusted) Throughput)
PM10 0.0075 8.5 AP-42 Table 1.4-2(PMIO/PM:2.5)
PM2.5 0.0075 _ 8.5 AP-42 Table 1.4-2(PM10/PM.2.5)
SOx 0.0006 0.7 AP-42 Table 1.4.2 1505)
NOx 0.0680. 77.2 AP-42 Chapter 13.S Industrial Flares(NOx)
VOC 0.0054 6.1 AP-42 Table 14-2(VOC)
CO 0.3100 352.2 AP-42 Chapter 13.5 industrial Flares(CO)
Section 05-Emissions Inventory
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year) (tons/year( (tons/year) (tons/year) (lbs/month)
PM10 0.1 0.1 0.1 0.1 0.1 22.0
PM2.5 0.1 0.1 0.1 0.1 0.1 22.0
50x 0.01 0.01 0.01 0.01 0.01 1.7
NOx 2.30 1.93 1.93 2.30 2.30 390.67
VOC 529.31 441.09 22-06 529.31 26.47 4496.81
CO 4.85 4.12 4.12 4.85 4.85 823.57
Potential to Emit Actual Emissions Requested Permit Limits
3 of 9 K:\PA\2019\19WE0186.CPZ
Storage Tank(s)Emissions inventory
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
Ube/year) (lbs/year) (Ibs/year) (lbs/year) (lbs/year)
Benzene 2263 1886 94 2263 113
Toluene 3013 2511 126 3013 151
Ethylbenzene 89 74 4 89 4
Xylene 1115 929 46 1115 56
n-Hexane 22627 18856 943 22627 1131
224TMP 61 51 3 61 3
•
•
4 of 9 K:\PA\2019\19 W E0186.CP2
Storage Tank(s)Emissions Inventory
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,B Source requires a permit
Regulation 7,Part D,Section I.C,D,E,F Storage tank is subject to Regulation 7,Part D,Section LC-F
Regulation 7,Part D,Section I.G,C Storage Tank is not subject to Regulation 7,Section I.G
Regulation 7,Part D,Section 11.B,Cl,C.3 Storage tank is subject to Regulation 7,Part D,Section II,8,C.1&C.3
Regulation 7,Part D,Section ll.C.2 Storage tank is subject to Regulation 7,Part 0,Section ll.C.2
Regulation 7,Part D,Section II.C.4.a(i) Storage Tank is not subject to Regulation 7,Part 0,Section II.C.4.a(i)
Regulation 7,Part D,Section ll.C.4.a.(ii) Storage Tank is not subject to Regulation 7,Part 0,Section ll.C.4.a(ii),b-f
Regulation 6,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb
Regulation 6,Part A,NSPS Subpart 0000 Storage tank is not subject to NSPS 0000.
NSPS Subpart 0000a Storage Tank is not subject to NSPS 0000a
Regulation 8,Part E,MACE Subpart HH Storage Tank is not subject to MAR HH
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
For condensate or crude oil tanks,does the company use the state default emissions factors to .
estimate emissions?
If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons VOC per year OR are the
uncontrolled actual or requested emissions far a condensate storage tank estimated to be greater than or equal to 80 toy?
If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash missions,are the emissions factors based on a pressurized liquid sample drawn at the fist hty being r
permitted(for produced water tanks, pressurize liquid sample must be analyzed using flash liberation analysis).This sample :
should be considered representative which generally means site specific and collected within one year of the application received u �,
date.However,0the facility has not been modified(e.g.,no new wells brought on line),then it maybe appropriate to use an
older site-specific sample. Yest,
If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
# `[
Does the company request a control device efficiency greater than 95%for a flare or combustion device?
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02
Section 08-Technical Analysis Notes
1.Site-specific Emission Factors:The site specific sample used to establish emissions factors for this source was obtained within a year of the first issuance application.The sample was obtained from the]Clark 13N
well.This well is one of the twenty-one(21)wells drilled at this facility and there were no significant changes to the Maly since the development of the emissions factors.Asa result,the permit will not require initial
testing in order to obtain a new site speciPcsample It should be noted that the sample includes sample probe temperature aid pressure in conjunction with gauge pressure and:temperature.
2.Secondary Emissions Calculations:
2.1 Operator used the following equation to calculate:the annual heat input.
Heat input(MMBtu/yr)=[Uncontrolled VOC(ton/yr)].[2000(lb/ton)]4.-MW(lb/ibmoI)*[379.41(scf/IbmoI)].[1/VOC mot Vol [Heat Content(Btu/scf)]_[1MMBtu/(1000,000 Btu)].
The values used in the equation were obtained from a Pro Max simulation used to calculate emissions and develop emission factors.The values used areas follow:(i)Molecular weight:46.2lb/Ib-mol,(iii VOC mot%:
70.7°.6,(iii)Heat Content:2593.2 Btu/scf.
3.Pilot Light Emissions Calculations:Operator assumed pilot fuel to have the same conditions of field gas which is consistent with the plant design provide by operator.The permit will not contain m Rol or periodic
opacity testing for the enclosed comhustor(s)because the O&M plan approved for this source requiresweeklyvisible emissionsobservations of the enclosed combustor(s).A throughput limit is included in the permit
for pilot combustion.Emission factors and calculation methods for pilot light combustion emissions are also included in thenotes to permit holder.This information is included in the permit because pilot light
emissions contribute to the overall emissions from this source.Additionally it is important to include this information becase throughput tracking and emission calculation methods are different than those used to
estimate emissions based on the condensate throughput.This clarity is important for accurately quantifying actual emissionsat this facility.
Section 09-5CC Coding and Emissions Factors[For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process it 5CC Code Pollutant Factor Control% Units
001 01 4-04403-11 Fixed Roof Tank,Condensate working+breathing+flashin0 los es �y �'. PM10 0.03 0 lb/1,000 gallons Condensate throughput
PM2.5 0.03 0 lb/1,000 gallons Condensate throughput
SOx #REFI 0 Ib/1,000 gallons Condensate throughput
• Nog 0,45 0 16/1,000 gallons Condensate throughput
VOC 102.99 95 Ib/1,000 gallons Condensate throughput
CO 0.94 0 lb/1,000 gallons Condensate throughput
Benzene 0.22 95 lb/1,000 gallons Condensate throughput
Toluene 0.29 95 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons Condensate throughput
Xylene 0.11 95 lb/1,000 gallons Condensate throughput
n-Hexane 2.20 95 16/1,000 gallons Condensate throughput
224 TMP 0.01 95 lb/1,000 gallons Condensate throughput
5 of 9 K:\PA\2019\19WE0186.CP2
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
',vice 1.in_.,In,.Aawfmnera Area
ATTAINMENT
1. Are uncontrolled actual emissio.e from any criteria pollutants from this individual source greater than 2TPY(Regulation 3,Part A,Section 11.0.1.x)? Source Requires an APEN.Go to
2. Is the construcgon date Nervicertatelpl to 12/30/2002 and notmdiFld after 12/31/2002(See PS Memo 05-01 Definitions 1.12 end1.14 and Section 2 for additional guidance on grandfather applicability)? �An to next 9vest on
3. Are total facility uncontrolled VAC emissions greater than 5TPY NOx g atr than 1OTPY or CO emissions greaterthan l0TPY(Regulation 3,Part B,Section l l.D3]? Source Requires a permit
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section 11.0.1.8(? t"dAhoIW*'Source Requires an APEN.Go to
2. Is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)? ia4RIgnaila Go to next question
3. Are total facility uncontrolled VOL emissions greeter than 2TPY,NOx greater than 5TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 11.0.2)? 't Source Requires a permit
Colorado Regulation 7.Part 0,Seotisn1.C-F&G
1. Isthisstorage tank located in the 8-hr ozone control area.or any ozone non-attainment area orattainmem/maintenance area(Regulation 7,Part D,Section 1-0.1)7 Continue-You have indicated th
2. Is thisstoragetank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located g or upstream of a natural gas processing plant(Regulation 7,Part D,Section 1-0.1)? Continue-You have indicated th
3. Is this storage tank located eta natural gas processing plant(Regulation 7,Part D,Section 1.0)7 fic Storage Tank is not subject to Re
4. Does this storage tank contain condensate? yen
5. Does this storage tank exhibit"Flash"(e.g.noring non-stabilized liquids)emissions(Regulation 7,part D,Section 1.0.2)7 Yes -
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tans per year VOC(Regulation],Part O,Section 1.0.3.a(ii((4
I5ivr nO tanxicsuhler Ic RevV.a don'),` i,-_Part 0,Section 1.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part 0,Section rC,2—Emusion Estimation Procedures
Part 0,Section 1.0—Emissions Control Requirements
Part e,Section l.E—Monitoring
Part D,Section I.F—Recordkeeping and Reporting
ve Tank is nor s,='.!-!to Regulation Y Section:::
Part D,Section I:G.2-Emissions Control Requirements
Pan 0,Section I.C.1.a and b—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Colorado Regulation].Part D.Section',
1. Is this storagetank located at a transmisslon/storage facility? Na Continue-You have indicated th
2. Isthis storage tank'located at an oil and gas exploration and production operation,wet productionfaciloy',natural gas compressor stations or natural gas processing plant°(Regulation 7,Pert D,Seater ll.C)? You Go to the next question-You he
3. Does this storage tank have a fixed roof(Regulation 7,Part D,Section ll.A.20)7 "taa.aW.Go tothe next question
4. Are uncontrolled actual emissions of this storage tank equal[oor greater than 2tons per year VOC(Regulation],Part D,Section ll.C.i.c)7 lagda5ource is subject to parts of Reg!
ISt_-..,.e t -. N.n.,nin,!I N.L_R,C3
Part D,Section(LB—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section ILC.1-Emissions Control and Monitoring Provisions
Part 0,Section ILC.3-Recordkeeping Requirements
5. Does the storg t k contain onlestabiliied"liquids(Regulation 7,Part 0,Section il.C2.b)? d hijSource s subject to all provision:
Pang,Section ll.C.2 Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storagetankl d at a well production facility,natural g pressor station,or natural gas processing plant constructed on or after May 1,2020 or located at a facdiy that was modified on or after May 1,2020,such
6 that an additional controlled storage vessel N constructedt p tad increase mthroughpat of hydrocarbon liquids or produced water(Regulation 7,Part D,Section lI 431')? Na '>"",:"`.Storage Tank is not subject to Ha
Is the controlledstarage tank located at a well production facility,natural gas compressor station,or natural gas processing plant consemeed on or afterlanuary 1,2021 or located at a facility that was modified on or after-January 1,
7. 2021,such that an additional controlled storage vessel is constructed to receive an anticipated increase lnthroughput of hydrocarbon liquids or produced water(Regulation 7,Part 0,Section II.C.4.alii)? No.........,
Is ei rF_ t dnt7.riart fraffiantifa.e il.h
40 CFR.Pert..Subpart Kb,Standards of Performancefor Volatile Organic squid Storage Vessels
1. Is the individual storage vessel capacity greater than orequel to 75 cubic meters(m51['472 BBLsl(40 CFR 60.110blal)? Oct ,.Go to the next question
2. Does thestoragevessel meet the following exemption in 60.111b(d)(4)? .^s Storage Tank is not subject NSPS
a.Does the vessel has a design capacity less than or equal to 1,589.874 ms["10,000 BBL]used for petroleum'.or ondensate stored,processed,or treated priorto custody transfer'as defined in 60.11lb?
3. Was this storage vessel constructed,reconstructed or modified(seedefinitions 40 CFR,60.2]after July 23,1984(40CFR 60.1106(3))? k3 ?v
4. floes the tank meet the definition of"storage vessel"'in 60.111b? N 'st:'
t.�n',
5. Doesthe storage vessel store a"volatile organic liquid(VOL)"sas defined in 60.11lb? aµ==.sf '
6. Does the storage vessel meet any one of the following additional exemptions: Agakfi
a.Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa[^292 psi]and without emissions to the atmosphere(60.110b(d)(2)]7;or
b.The design capacity is greater than or equalto151m'["950 BBL]and stores a liquid with a maximum true vapor pressure less than 3.5 kwa(6o.11oblb))?;or
c.The design capacity is greater than or equal to 75 M°["472 BBL]but less than 111 m'(-910 BBL]and stores a liquid with a maximum true vapor pressure'less than 15.0 kPa(60.110b(b)1? fl. n4^
7. Does the storagetank meet ether one of the followingexemptlons from control requirements: hViCRiMARW.fi
a.The design capacity Is greater than or equal to 1510'[-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 35 kPa but less than 5.2 kPa?;or u3 Fa5a a1f
b The design capacityls greeter than or equal to 75M I-472 BBL]but Iess than 151m'I-950 BBL].and stores a liquid with a maximum true vapor pressure greeter than or equalto 150 kPa but less than 27.6 kPa7 ABM S'
I5rcno cT'anlcisnots!,,p_:ls
40 CFR.Part 60.Subpart 0000/0000n.Standards of Performance for Crude Oil and Natural Gas Froductlon,TeansmIsslon and Distribution
1. Is this storage vessel located at a facility In the onshore oil and natural gas production segment,natural gas processing segment or natural gas transmission and storage segment of the industry? Yes Continue-You have indicated tit
2. Was this storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)between August 23,2011 and September 18,2015? h.14.fi!`'•.'i/Storage Tank Is not subject NSPS
3. Was this storage vessel constructed,reconstruoed,or modified(see definitions 40 CFR,60.2)after September 68,2015? S,."+-..-Go to the next question
4. Are potential VOC emissions'from the individual storage vessel greater than orequaito 6 tons per year? WIN Storage Tank is not subject NSP5
S. Does this storage vessel meet the definition of"storage vessel"'per 60.5430/60.54305?
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CfRPan 60 Subpart Kb or 40 CFR Part 63 Subpart HH? WOO*
ISI f .sriot .,.-VS.iV
[Note:If a staragevessel is previously determined to be subjectto NSPS 0000/0000e due to emissions above 6 tans per year VOC on the applicability determination date,it should remain subject to SOPS 0000/0000a per
60.5365(e)l2)/60.965a(e](2]even apotemlal VOC emissions drop below 6 tons peryearj
00 CFR,Part 63,Subpart MACT HH,Oil and Gas Production Facilities .
1. Is thestaragetank located at an oil and natural gas production fadley that meets either of the fallowing criteria: iftia 'Continue-You have indicatedth
a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760(a)(2)(i OR
b.Afacildy that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user'I63.760(a)l3)1?
2. Is the tank located at a facility that 6 major'for HAPs? Wr4ViiStorage Tank/s not subject MAC
3. 0aes the tank meet the definition of"storage vessel"'in 63.761?
4. Does the tank meet the dehndion of storage vessel with the potential for flash emGsmns"°per 63.]61?
5. Is the tank subject lo control requirrtnentsunder 40 CFR Part 60,Subpart Kb or Subpart 0000? ;4Arb1vF'.
subpartA,General provisions per 463.764(a)Table 2 '
463.766-Emissions Control Standards
463.773-Monitoring
463.774-Recordkeeping
063.775-Reporting
RAM-Review
RACT review is required If Regulation 7 does not apply AND ff the tank is in the non-attainment area.If the tank meets both criteria,then review RACT requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not
a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any Into regulation,
r 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,""rosy,'°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 AirAct and Alr
Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself.
•
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name PDC Energy,Inc.
County AIRS ID 123 History File Edit Date 11/18/2020
Plant AIRS ID 9F4F _ Ozone Status Non-Attainment
Clark 14 Sec HZ;J Clark 14 Sec HZ
Facility Name
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS
AIRS VOC HAPs VOC HAPs
ID
Previous FACILITY TOTAL 1.3 1.3 0.0 0.0 186.5 1.224.6 0.5 179.0 34.9 1.2 1.2 0.0 0.0 21.6 76.3 0.5 37.0 3.6
Previous Permitted Facilil,total 0.9 0.9 _ 0.0 0.0 181.5 1.224.0 0.0 174.7 34.7 0.8 0.8 0.0 0.0 16.6 75.7 0.0 32.8 3.4
001 1971150186 Twenty-six(26)538 bbl fixed roof 2.3 529.3 4.8 14.6 2.3 26.5 4.8 0.7 Point updated an 10:13:2020 DC 10;13:2020
condensate storage vessels -
002 GP05.CN.XA `Fourteen(14)400 bbl and three(3) 0.3 - - - 0.0 0.3 0.0 Cancellation request received 2/19/19.Emissions are
210 bbl fixed roof produced water below APEN reporting thresholds.
storag@vessels -
003 20WE0755 Condensate Loedout 0.1 28.9 0.3 0.5 0.1 1.4 0.3 0.0 Point updated on 10/13/2020.DC 10;13/2020
004 GP02.ON RICE GM Vortec 5.7L 4SRB(86 HP 0.0 0.0 Cancellation request received 10123117.Source no longer
site rated)SN:10CHMM502250035 exists at the facility.
005 GP02 RICE GM Vortec 5.7L 4SRB(88 HP 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No Change
site rated)SN:10CHMM612060012
006 GP02 RICE GM Vortec 5.7L 4SRB(88 HP 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.9 0.6 1.7 0.1 No Change
site rated)SN:13219148
007 GP02.CN Si RICE Caterpillar G3306TA,4SRB, 0.0. 0.0 Cancellation received on 08128/2020.
211 HP,SN:G6X07367
008 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 0.0 Cancellation received 10/31/19.Source no longer exists
211 HP,8N:G6X57743 atthe facility.
009 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 0.0 Cancellation received 10/31/19.Source no longer exists
211.HP,SN:G6X08437 at the facility.
010 GP02.CN SI RICE Caterpillar G3306TA,4SRB, 0.0 0.0 Cancellation received on 08/28/2020.
211 HP,SN:G6X07312
011 GP02 SI RICE GM Vortec 5.7L,4SRB,87.5 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.8 0.6 1.7 0.1 No Change
HP(site rated),SN:
10CHMM40610045
012 GP02 SI RICE GM Vortec 5.7L,4SRB,87.5 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0.1 0.8 0.6 1.7 0.1 No Change
HP(site rated),SN:
10L59M711220040
013 GP02.CN SI RICE Caterpillar G3406TA,4SRB, 0.0 0.0 Cancellation received 11/15119.Source no longer ex)sts
276 HP,SN:CRE00194 at the facility.
014 GP02 SI RICE MOW GM 9.0L,4SRB,136 0.1 0.1 16.0 3.5 14.6 0.2 0.1 0.1 1.3 0.9 2.6 0.2 No Change
HP(site rated).SN:296724
015 GP02 SI RICE Caterpillar G3306NA,4SRB, 0.1 0.1 18.6 1.3 18.6 0.4 0.1 0.1 1.4 1.0 2.7 0.3 No Change
138 HP(site rated),SN:G6X08969
016 GP02,CN. ' SI RICE Caterpillar G3308NA,45RB, ' 0.0 - 8.5 Cancellation received on 08/28/2020. ".
138 HP(site rated),SN:R6S016))
XA External Combustion Sources 0.4 0.4 5.0 0.1 4.2 0.0 0.4 0.4 5.0 0.1 4.2 0.0 Insignificant Sources
XA Fugitives 0.5 0.1 0.5 0.1 Insignificant Sources
XA Produced Water Tanks 0.2 0.0 0.2 0.0 Insignificant Sources
FACILITY TOTAL 0.8 0.8 0.0 0.0 89.4 565.9 0.5 79.6 16.2 0.8 0.8 0.0 0.0 13.7 32.8 0.5 21.4 1.8 VOC: Syn Minor(NANSR and OP)
NOx:Syn Minor(NANSR and OP)
CO:Minor(OP),Minor(PSD)
HAPS:Syn Minor(n-Hex)
NH:Area source-no affected sources
ZZZZ:Area source
Permitted Facility Total 0.5 0.5 0.0 _ 0.0 84.3 ,565.4 0.0 75.4 16.1 0.5 0.5 0.0 0.0 8.6 32.2 0.0 17.2 1.7 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.4 -0.4 0.0 0.0 -8.0 -43.4 0.0 -15.6 -1.7 Pubcom required because source is attempting to obtain
a federally enforceable limit on the potential to emit in
order to avoid other requirements.Modeling not required.
Total VOC Facility Emissions(point and fugitive) 33.2 Facility is eligible for GP02 because CO<90 ipy and
NOX/VOC<45 Inc.
(A)Change in Total Permitted VOC emissions(point and fugitive) -43.4 Project emissions less than 25 ipy(NOx and VOC)and
less than 50 tpy(CO).
Note 1
Note 2
Page 8 of 9 Printed 11/18/2020
COLORADO DEPARTMENT-OF ENVIRONMENT
AIR POLDNDN DIVISION
FACILITY EMISSION SDMMAM'-NMi
Compose'Name FOG Seamy.Inc.
Gnu.AIRS ID 123
Plant AIRS(0 9F4F
Fealty Name Clink 14 Sec HZ:J Clark 14 Sac HZ
Emissions-uncontrolled(Iles per veer)
POINTIPERMIT IDescr'1don 10 en2 a=4.ware.0201011 7072080 Toluene REorreme1•%Banes n-Hexane Me0H 224 IMP H2S
prevla11us FACILITYTO—AL _ 16 _ 0,] 0.1 2.7 _ 3.4 0,1 12 _25.6 01 01 00 60 340
DOI 15WE0166 Tvrenlyalx(2B)538 bbl fixed roof 2262.8 3012.7 o... 1117 7 22627 3 146
.storaoe vessels
002 GP65CNXA o,,ol0ed)rOU Wod Zed 37(3) .. , 00
storace?533(5075 testes n5
0'+ 8008005/ PP35
00d 0802 COI RICE SN 10 HWIL 550(8802250 HP 00
si@mtpd)6N.10Q1MM502256635
005 G1802 RICE GM Vortec 57L 4SRB(BB HP ,., 01
site rated)SN'.10CHMMs12060012
006 GP02 RICE GM Ocoee 57545RB(88 HP 01
site rate. e 3210140
607 0000(58 Cale...0 306TH SRB 0.0
11 a
P;6N'G G530756(
003 Gv02CN 211 X5 C6TA,4688. 00
211 HP StrG 6%07730843
009 0802 ON 57,7(,Ster fryer G3506TA,4SRB 00
2I B E cater,X08137
010 GPO2 CN 011 HP Caterp 5 7312 4SRB, 00
SHIP GMvo X07312
DIt GPM 257E 4SRB. ,., 7N 0.1
67 5 HP(sire rated),SN
IIRIcESM\fo045
012 0802 IRICE GM Vodec 57L.4SRB, r0 13 0 1
17.5 HP(site mt040 SR'
1 L5CE711220040
019 GP02 C11 SI HP GI.CPIE0G340GT(k049R8 90
6
015 OP02 SI RICE Caleryla 03300NA,dSRB. 746.1 _i. 04
138 HP(sire rated),SN'.G6%08969
016 GPO2.CN SI RICECaler(90ar G3306NA:4SRB 0.0
138 HP(dle,ratp4))t8N R6S01011
External bastion Soures
01
%A Produced Water Tanks I n 0 C 111 0.0
TOTAL((DO 53 0.1 0.1 1.3 1.6 0.1 fie 11.6 0.1 0.0 0.0 0.0 161
'Total Reportable=all HAP.where uncontrolled emissions.de minimus valu.
Emissions with controls(Ibsper year
POIN PERMIT IOescrpdon rmwenre 00.5,50,Acreleln 8072050 Toluene 6NW.Nm•%Banes n-Hexane Me02 224 IMP Hun
101
Previous FACILITY TOTAL 1.3 0.1 0.1 0.3 0.2 0,0 0.1 1.3 0.1 OD 0.0 0.0 36
001 19WE0166 Twe812.7(28)538 LW dxetl roof 1131 1506 (. 55.9 11314 0.7
denseii st ssels
002 GP05.CN:%A ('wri 7.X)4WbWarlVlAea(3) -il S t1 00
210 bbl vessels
roKprMuced wakr
WE00 nM8*0052 44.2 03 20 donee 00
004'GPOZ.CN RICE GM SN 100751,502289 HP Co
site rated)SN.tOCHMM502250035
005 GP02 RICE GM Vode05.7L 4SRB(88 HP '„ 5, 0.1
slie rated)SN:IOCHMM612060012
006 CP02 RICE GM Vodec 5.)L 4SkB(88 HP 16. .. ,. 0.1
ode e15N 132191.
00T GP02:CN 21 RHPSNaG6X6,6�08TAWBRB LTO"
CON PO2CN (RICE CatmPiOaiC RB. 0.0
E
�N 66X0774 xT
Y109 GPOJ..Ct4 G330848.:4SRB OD
11 HP P SN G0.06437
010 CP02.CN SI RICE 3300TH,4SRB. 00
211 HP.SNeO5X0731?
011 GP02 SI RICE GM Voile.5 7,4SRB, 2 0.1
87.5 HP fele stab),SN'.
10CHMM40010045
012 GP02 SI RICE GM VORec 52L,4SRB. ..Zs .7 •.. 0.1
67 5 HP(site reled),SN'.
10456617112291040
013 0102 C SIRCECeterplerG3406TA.4SRB 00
276 HP,SN'CREW194
014 GP02 SI RICE MOW GM 9 OL,45RB,136 149. _e 4 11::: a. .. 02
HP(see Wen SN.2 724
015 GP02 SI RICE Caterpillar G2306NA,4SRB, 5866 _:._ ...v 171 - 0.3 138 HP(see ratetl)SN G6%08969
018 ,?r?,CW 5(0 CE Cate G 3 N 6R
Y$s s� 939 HP Isiie ra'1)DN R5501611 e 00
External Combustion Sources D
XA Fugitives :O'I 0,1
XA Produced Water Tanks +I 00
TOTAL 01171 e] 0.1 0.1 0.1 0.1 0.0 O 0,6 0.1 0.0 0.0 0.0 1.8
s 19wEo16s.CP2 a/0510000
M.,., COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 20WE0755 Issuance: 1
Date issued: XX/XX/XXXX
Issued to: PDC Energy, Inc.
Facility Name: Clark 14 Sec HZ; J Clark 14 Sec HZ
Plant AIRS ID: 123/9F4F
Physical Location: NWNE Quadrant of Section 14, Township 5N, Range 65W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
Equipment Description
ID Point Description
LOAD-1 003 Truck loadout of condensate by Enclosed Combustors
submerged fill
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
Page 1 of 10
CCr�Y:.� COLORADO
0 i Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
AIRS Tons per Year Emission
Equipment ID
Point PM2.5 NO,t VOC CO Type`
LOAD-1 003 --- --- 1.4 --- Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on
the previous twelve months' data. The permit holder must calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
6. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Equipment AIRS Control Device Pollutants Controlled
ID Point
LOAD-1 003 Enclosed Combustors VOC and HAP
Page 2 of 10
r•- COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PROCESS LIMITATIONS AND RECORDS
7. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rate must be maintained by the owner or operator and made,
available to the Division for inspection upon request. (Regulation Number 3, Part B, Section
II.A.4)
Process/Consumption Limits
Equipment ID AIRS Process Parameter Annual Limit
Point
LOAD-1 003 Condensate Loaded 244,728 barrels
The owner or operator must calculate 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
8. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.1. Et 4.)
9. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
10. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control
equipment. Compliance with Section II.C.5. must be achieved in accordance with the following
schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to
5,000 barrels per year on a rolling 12-month basis must control emissions from loadout
upon exceeding the loadout threshold.
11. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7,
Part D, Section II.C.5.a.(ii))
Page 3 of 10
r:,.. COLORADO
• 4 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
12. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles
and to route the vapors to the storage tank or air pollution control equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back-pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless loadout
occurs less frequently, then as often as loadout is occurring.
13. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect the
facility within 24 hours after loadout to confirm that all storage tank thief hatches (or
other access point to the tank) are closed and latched."'
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
14. The owner or operator must retain the records required by Regulation Number 7, Part D, Section
II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon
request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution, required
under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
Page 4 of 10
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Records of the annual training program, including the date and names of persons
trained.
15. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
16. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING a MAINTENANCE REQUIREMENTS
17. Upon startup of these points, 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 your 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
18. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
19. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
20. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit Existing Emission Point New Emission Point
Number
GP07 123/9F4F/003 123/9F4F/003
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section II.C.)
Page 5 of 10
r COLORADO
411, 440 lite Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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 (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.
For any non-criteria reportable pollutant:
If the emissions increase by 50%or five (5) tons per year, whichever is less, above
the level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process,or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
22. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D)
GENERAL TERMS AND CONDITIONS
23. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
24. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
Page 6 of 10
C4. :Y:: COLORADO
4Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
26. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
27. Each and every condition of this permit is a material part hereof and is not severable.Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
28. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Diego Chimendes
Permit Engineer
Permit History
Issuance Date Description
Page 7 of 10
r•,,. . COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Issued to PDC Energy, Inc. Operator requested
Issuance 1 This Issuance change of coverage from GP07 to an Individial
Permit.
Page 8of10
,.r. COLORADO
iii L Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: >. ,, _ ,. a - -I .
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 102 5
003
n-Hexane 110543 883 44
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:
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors
lb/bbl lb/bbl
V0C 2.36x10-1 1.18x10.2 PS Memo 14-02
n-Hexane 110543 3.61x10-3 1.81x10-4 PS Memo 14-02
Page 9 of 10
CCr:•r COLORADO
0 Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN must be submitted no later than 30 days before the five-year term expires. Please refer to
the most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division
at (303)-692-3150.
7) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, NOx, Et n-Hexane. True Minor
Source of CO.
PSD True Minor Source of: CO Et NOx
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 website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
Colorado Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Diego Chimendes
Package d: 434903
Received Date: 8/27/2020
Review Start Date: 310/13/2020
Section 01-Facility Information
Company Name: PDC Energy,Inc. Quadrant Section Township Range
County AIRS ID: 123 NWNE 14 SN 65
Plant AIRS ID: 9F4F
Facility Name: Clark 14 See HZ;J Clark 14 See HZ
Physical
Address/Location: NWNE quadrant of Section 14,Township 5N,Range 65W
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
Permit#
AIRS Point# Emissions (Leave blank unless Issuance Self Cert Engineering
(Leave blank unless APCD Emissions Source Type Equipment Name Action
Control? APCD has already # Required? Remarks
has already assigned)
assigned)
Permit Initial
003 Liquid Loading LOAD-1 Yes 20WE0755 1 Yes Issuance
Section 03-Description of Project
PDC Energy,Inc.(PDC)submitted an application on 08/27/2020 to change coverage of condensate loadout activity from GP07 to a traditional permit.
This point source is APEN-required because uncontrolled VOC emissions are greater than 1 tpy and uncontrolled emissions of at least one non-criteria pollutant is
greater than 250 tpy.(Regulation 3 Part A Section 11.8.3.)Point source is permit-required because uncontrolled facility-wide VOC emissions are greater than 2 tpy.
(Regulation 3 Part B Section,II.D.2.).'
This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in order to
avoid other requirements:(Regulation 3 Part B Sections III.C.1.d.).
Point source is not subject to ambient air impact analysis.(Regulation 3 Part D Section II.A.44).
Sections 04,05&06-For Division Use Only
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD)Title V Operating Permits(OP) ✓ ✓ — CI
Non-Attainment New Source Review(NANSR) ✓ ✓
Is this stationary source a major source? No
Colorado Air Permitting Project
If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) _
Title V Operating Permits(OP) _ _ ❑
Non-Attainment New Source Review(NANSR)
Hydrocarbon Loadout Emissions Inventory
Section 01-Administrative Information
Facility AIRS ID: 123 9F4F 003 I
County Plant Point
Section 02-Equipment Description Details
Detailed Emissions Unit Truck loadout of condensate by submerged fill.
Description:
Emission Control Device One(1)Cimarron 60"Enclosed Combustor Device.
Description:
Is this loadout controlled? Yes
Requested Overall VOC&HAP Control Efficiency%: -.95
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Hydrocarbon Loadout
Actual Volume Loaded= 203,940 Barrels(bbl)per year
•Requested Permit Limit Throughput= - 244,728 Barrels(bbl)per year Requested Monthly Throughput= 20785 Barrels)bbl)per month
Potential to Emit(PTE)Volume Loaded= 244,728 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
' Heat content of waste gas= 2593.2 Btu/scf
Molecular Weight= 46.2 Ib/Ibmol
VOC mol%= 70.67%
Molar Volume= 379.4 scf/Ihmol
Actual Volume of waste gas emitted per year= - 558908 scf/year
Requested Volume of waste gas emitted per year= 670688 scf/year
Actual heat content of waste gas routed to combustion device= 1,449.4 MMBTU per year
Requested heat content of waste gas routed to combustion device= 1,739.2 MM BTU per year
Potential to Emit(PTE)heat content of waste gas routed to combustion device= 1,739.2 MM BTU per year
Control Device L 1
Pilot Fuel Use Rate: mp` iS; ,;C'.s156.,scfh 0.1 MMscf/yr
Pilot Fuel Gas Heating Value: ,e70136(Btu/suf 155.2 MM BTU/yr
Section 04-Emissions Factors&Methodologies •
Does the company use the state default emissions factors to estimate emissions? e-+
Does the hydrocarbon liquid loading operation utilize submerged fill? 1-`.'a -z The state default emissions factors may he used to estimate emissions.
Emission Factors Hydrocarbon Loadout
Uncontrolled Controlled
Emission Factor Source
Pollutant (lb/bbl) (lb/bbl)
(Volume Loaded) (Volume Loaded)
VOC 2.36E-01 1.18E-02 .R eF
Benzene 4.16E-04 2.08E-05 - C.F.
Toluene 0.00E+00 0.00E+00 ` ;..
Ethylbenzene 0.00E+00 0.00E+00
%ylene 0.00E+00 0.00E+00 r.
n-Hexane 3.61E-03 1.81E-04
224 TMP 0.00E+00 0.00E+00
Control Device
Uncontrolled Uncontrolled
Pollutant Emission Factor Source
(ib/MMBtu) (lb/bbl)
(waste heat combusted) (Volume Loaded)
PM10 0.0075 5.30E-05 AP-42 Table 1.4-2(PM1O/PM.2,5):
PM2.5 0.0075 5.30E-05 AP-42 able 1.4-2(PM10/PM.2.5)�stny
500 0.0006 4.18E-06 AP-427evre 0.4-2(50x)
NOx 0.1380 9.81E-04 TNRCC Flare Em?sons Guidance(500)
CO 0.2755 1.96E-03 TNRCC Flare Emissions Guidance{CO) =
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source
(Pilot Gas
(Waste Heat Combusted) Throughput)
PM10 0.0075 8.4643 2 Tablet M10/PM.2.5)
PM2.5 0.0075 8.4643 Al0-42 Table l.4-E(PM10/PM.2.5)
SOx 0.0006 0.6682 AP-42 Table 1.4-2(SOx)
3 of 6 K:\PA\2020\20WE0755.CP1
Hydrocarbon Loadout Emissions Inventory
NOx 0,0680 77.2480 AP-42 Chapter 13.5 Industrial Flares(NOx)
VOC 0.0054 6.1255 AP-42 Table 1.4.2fVOC)
CO : 0.3100 352.1600 AK042 Chapter 13.5 Industrial Flares(CO)
4 of 6 K:\PA\2020\20WE0755.CP1
Hydrocarbon Loadout Emissions inventory v
Section 05-Emissions Inventory ,
Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits
Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled
(tons/year) (tons/year( (tons/year) (tons/year) (tons/year) (lbs/month)
PM10 0.01 0.01 0.01 0.01 0.01 1 ,
PM2.5 0.01 0.01 0.01 0.01 0.01 1
sox 0.00 0.00 0.00 0.00 0.00 0
NOx 0.13 0.11 0.11 0.13 0.13 21
VOC 28.9 24.1 1.2 28.9 1.4 245
CO 0.26 0.22 0.22 0.26 0.26 45 l
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (Ibs/year) (Ibs/year) _(lbs/year( (Ibs/year)
Benzene 102 85 4 102 5
Toluene 0 0 0 0 0
Ethylbenzene 0 0 0 0 0
xylene 0 0 0 0 0
n-Hexane 883 736 37 883 44
224 TMP 0 0 0 0 0
Section 06-Regulatory Summary Analysis
Regulation 3,Parts A,8 Source requires a permit
Regulation 7 Part D Section II.C.5. The hydrocarbon liquids loadeut source is subject to Regulation 7 Part D Section II.C.5.
(See regulatory applicability worksheet for detailed analysis)
Section 07-Initial and Periodic Sampling and Testing Requirements
/ ski,,...
Does the company request a control device efficiency greater than 95%for a flare or combustion device? "�
If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20.02
Section 08-Technical Analysis Notes
1.secondary Emissions Calculations:Operator used the following equation to calculate the annual heat input.
ffeat Input(MMBtu/yr)_[Uncontrolled V0C(ton/yr)]c[2000(lb/ton)]+MW(lb/lbmol)o[379.41(stf/Ibmol)]c[1/VOC mot°M.[Heat Content(Btu/scf)]c[1MMBtu/(1000,000 Btu)]
Promos simulation results using the sample obtained from the Lory 11N well was used to calculate the heat imput from loadoutpperations.Values used in the equation are as follow:(i)Molecular weight:44.4 lb/Ibmol,(ii)VOC wt%:60.88%,(iii)Heat
Content:2460.49 Btu/scf Using thesevalues,the operator calculateda heat input of 1,759 MMBtu/yr: - 1
2.Loadout activities have a decicated enclosed flare and NOx and CO:emissions are below reporting levels.For that reason,the permit viii not contain NOx and CO limits...
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
AIRS Point# Process# SCC Code Pollutant Factor Control% Units'
003 01 4-06-001-32 Crude Oil:Submerged Loading Normal Service(5=0.6) PM10 0.00 0 15/1,000 gallons transferred
PM2.5 0.00 0 lb/1,000 gallons transferred
. SOx 0.00 0 lb/1,000 gallons transferred
NOx 0.02 0 lb/1,000 gallons transferred
VOC 5.6 95 15/1,000 gallons transferred
CO 0.05 0 lb/1,000 gallons transferred
Benzene 0.01 95 lb/1,000 gallons transferred
Toluene 0.00 95 lb/1,000 gallons transferred
Ethylbenzene 0.00 95 lb/1,000 gallons transferred
Xylene 0.00 95 lb/1,000 gallons transferred
n-Hexane 0.09 95 lb/1,000 gallons transferred
224 TMP 0.00 95 lb/1,000 gallons transferred
5 of 6 K:\PA\2020\20WE0755.CP1
Hydrocarbon Loadout Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions and throughput.
Colorado Regulation 3 Parts and a-ARON and Permit Requirements
'Rearm the on.pn Afla�,rnrinna
ATTAINMENT
Art uncontrolled actual emissions horn any criteria I
lutants tram Ws Individual source greater than 2 TRY IRegdla d.3,Part A Stn..IlA.l.a)?
a. Is the readout lotatedat an eploration anti product site(e.g.,well pad)(Regbl,.3,Port B,Section II.0.1.0?
3. Is the',clout loading less tha0,000 gallons(238 Bets)of crude oil per day on an annual average basis?
6. Is the loadout operation loading less 01 ,750 bids per year of condensate via splash fill?
IS Me loadout operation loading less 6,a,r1. from this individual source greater than l THY(Regulation 3,Part',setion II111-a), 'toae"on
2. Is the loadout located at en exploration aM product'onsite(e.g.,well pad)IRegNatlan3 PattB,Section 11.0.11 to the next question
IsNeloadoutoperaLonl®tine less than 10,000 gallons(238 Bets)M crude oil per day on an annual average basis? iMrtquestion
4. Is the loadout operation loading less than 6,750 oils per year of codensam via splash fill? -.Mi.:.
5. Is the loadaut operation less than 15 tar..300 bb s per of condensate via submerged all procedure? -"Ifit Go ton.qu.6on
6. p facility uncontrolled Icons from...roarer than 2 TRY,MU greater than 5 TRY or GO emissions greater than 10 TPY'Regulation 3,Part B,Sect.II.O.2)? Vi TM load..requires a permit
Colorado Regulation 7 Part['Section ILLS.
Is this condensate storage tank hydrocarbon liquids loadout located at a well production facility, gas compressorsgdon or natural gas pr.esting plant, -„ uezton 1. ,�,%Ga to q
2 0 facility have throughput offiytl b loadout vehicles greater Manor equal to50006arrels? Source Is subject to Regulation?Part OS Mn 0..c.5.
Section II.c.5a.lil-comraianre ithSectionoutV
.a..1 o without VergingOpera
Section .a.Iiid-loadout observationOcemtionand Training
SectionS.a.(y)-tea observations and Operator Training
.a.(vl-Records
tn
Se ti'.II.C.S.a(vi)-Requirements for Air Pollution Control Equipment
Disclaimer
This document assists operators with determining epplkability of certain requirements of Me Clean Air Act,its tmpknerdbg reguletlwu,and Air Quality Control Commission regulations.This document is rota
irk orreguletion,,and the eneys/s itcontains may not apply toe psrticulersituetlm based upon the if iuidrel!acre and circumstances.Tres Axunlent dons not charge o-substitute for any law,regurs/o.,or
any other legally blrirg requirement and is not regally enforceable.In the event dany confect between ire!srguage of this document end the language afire Chen Are Act„its implementing regulotions.
end Air Quality Control Commrsslon regulations,the language tithe statute or regulation will control.The use anon-mandatory language such as"recommeM,""may,""siould,"and"can,"is intended to
descdbe APCD interpretations and recommendations.Mandatory k terminology such as'must"and'isgwred'are intended to describe contmd/rlg requirements under lheternrs of the Clean Air Act and Air
Queety Control Commission regulations,but this dscumentdat net establish legally brnnng requrronsr is ern ardd ifseM.
Condensate Storage Tank(s) APEN
C4440 Form APCD-205
COPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source(e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc..). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 19WE0186 1 86 AIRS ID Number: 123 / 9F4F /001
3.P 1,1K i f.l'. API 4 _I.gnn i i ?id ,kb AiPS 1,DI
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Clark 14 Sec HZ; J Clark 14 Sec HZ
Site Location
Site Location:
NWNE Sec 14 T5N R65W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address2: Jack.Starr@pdce.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
434900
COLORADO
Form Zta t..or d�nSdt_ �_�_.: F .,,_ .. X41 Rw`v'IS1.(' 1 �a.u°�epie,. e
Permit Number: 19WE0186 AIRS ID Number: 123 I 9F4F/001
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 O GP08
If General Permit coverage is requested, the General Permit registration fee of$353.13
must be submitted along with the APEN filing fee.
-OR-
Q MODIFICATION to existing permit(check each box below that applies)
O Change in equipment ❑ Change company name3
❑Q Change permit limit ❑ Transfer of ownership's ❑ 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: Requesting new throughput limit and emissions limits for Construction Permit 19WE0186;
2019 Actual throughput; Emissions calculated using previously approved site-specific emission factors.
3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 4/27/2017
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: (] Exploration a Production(E&P)site ❑ Midstream or Downstream (non MP)site
Will this equipment be operated in any NAAQS nonattainment area? E3 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? ❑✓ Yes O No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? 0 Yes ❑ No
If"yes", identify the stock tank gas-to-oil ratio: 0.0077 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) . Yes ❑ No
805 series rules? If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions(per storage tank), or are uncontrolled actual i Yes ❑ No
emissions≥6 ton/yr(per storage tank)?
se,COLOR ADO
Form m AP CD-2O5 Condensate Storage rar d- '.PE` GF lsi r 2 l x.° aiw `mm
Permit Number: 19WEO186 AIRS ID Number: 123 /9F4F/001
pr Brie,_ ,V;-'CL) asior 1 3 ?ad r
Section 4- Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) -(bbl/year)
Condensate Throughput: 203,940 244,728
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 52.8 degrees RVP of sales oil: 12.7
Tank design: 0 Fixed roof ❑ Internal floating roof O External floating roof
Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First
Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production
(bbl) Storage Tank(month/year) (month/year)
TK-1 26 13,988 7/2018 4/2017
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 43386 Clark 14J-203 O
05 - 123 - 43388 Clark 14J-223 ❑
05 • 123 - 43387 Clark 14J-303 O
05 - 123 - 43384 Clark 14J-343 O
05 - 123 - 43385 Clark 14M-343 ❑
s Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.406028/-104.62607
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F) (ACFM) (ft/sec)
Indicate the direction of the stack outlet: (check one)
O Upward ❑Downward ❑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 cinches): Interior stack depth(inches):
❑Other(describe):
3 I ®�co►oa�oo
Form PAD 2115 a ?n>at- st:rz lfjr , <,j t�PERevision 'iLi7/20< ��
Permit Number: 19WE0186 AIRS ID Number: 123 /9F4F/001
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:
0 Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed(emissions vented): %
Pollutants Controlled:
VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Combustors Make/Model: 18 x 48"Cimarron, 1 x 60"Cimarron
Combustion Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2593.21 Btu/scf
Constant Pilot Light: El Yes ❑ No Pilot Burner Rating: MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
0 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)? 34.8 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
(COLORADO 4
Form APCD-205 Condensate Starai.T,�i:f ?) FP ,i;;jn ,
Permit Number: 19WE0186 AIRS ID Number: 123 /9F4F/001
•- e .."1....'(' S.+Y,.,u _ •. '.1.'dssv,ned P .');
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑No
If yes, describe the control equipment AND state the requested control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Overall Requested
Pollutant Control Equipment Description Control Efficiency
(%reduction in emissions)
VOC Enclosed Combustor 95%
NOx
CO
HAPs Enclosed Combustor 95%
Other:
From what year is the following reported actual annual emissions data? 201 9
Use the following table to report the criteria pollutant emissions from source:
Requested Annual Permit
Emission Factor? Actual Annual Emissions
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units ('4P-4!2, Emissions Emissions Emissions Emissions
Basis Mfg.,etc.) tonsl ar tons/ ear
(tons/year) (tons/year) (tons/year)) (tons/year)
)
VOC 4_3257 Ib/bbl ProMax 441 09 22.06 529 31 26.47
NOx 01380 Ib/MMBtu TCEQ N/A 1_93 N/A 2.30
CO 0.2755 Ib/MMBtu ICED N/A 4.12 N/A 4.85
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteriaEl 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
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions8
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.0092 lb/bbl ProMax 1,885.70 94.28
Toluene 108883 0.0123 Ib/bbl ProMax 2,51063 12553
Ethylbenzene 100414 3.64E-04 Ib/bbl ProMax 74.15(DM) 3.71(DM)
Xylene 1330207 00046 Ib/bbl ProMax 928.88 46.44
n-Hexane 110543 0.0925 lb/bbl ProMax 18,85596 94280
2,2,4-Trimethylpentane 540841 2.50E-04 lb/bbl ProMax 50.99(DM) 2 55(DM)
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
5 lO caao o
FarmAYCI % %% C'3tiaE'i.i Storagerl 'S?APEN Revision( J7Lu .auop,nrauu
Permit Number: 19WE0186 AIRS ID Number: 123 /9F4F/001
..: anK illy c alto; a =c E' 3AV-ZS iD1
Section 10 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
/Si ure of Legally Authorized Person (not a vendor or consultant) Date
Jack Starr Senior Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
❑Draft permit prior to issuance
ID 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.). Sere Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $216.00 and the General For more information or assistance call:
Permit registration fee of$353.13, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver,CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
COLORADO
'Orm AK)) 2.05 C ndePsa t Star 'ilfr ) APENP•4 iSi.,t L{.::'. 6 I
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: PDC Energy,Inc.
Source Name: Clark 14 Sec HZ;J Clark 14 Sec HZ
Emissions Source AIRS ID2: 123 I 9F4F/001
Wells Services by this Storage Tank or Tank Battery(E&P Sites Only)
API Number Name of Well Newly Reported Well
05- 123-46688 J Clark IC ❑
05-123-46691 J Clark 2N ❑
05-123-46686 J Clark 3N ❑
05-123-46687 J Clark 4N ❑
05-123-46694 J Clark 5N ❑
05-123-46690 J Clark 6N ❑
05- 123-46692 J Clark 7N ❑
05-123-46684 J Clark 8N ❑
05-123-46697 J Clark 9C ❑
05-123-46696 J Clark 10N ❑
05-123-46689 J Clark I IN ❑
05-123-46685 J Clark 12N ❑
05- 123—46695 J Clark 13N ❑
05-123-46693 J Clark 14N ❑
05- 123-46683 J Clark 15N ❑
05- 123-46682 J Clark 16N ❑
- - ❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212 TK-1 Addendum
•
Hydrocarbon Liquid Loading APEN
C
4440 Form APCD-2O8
CDPHE Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled
out incorrectly, is missing information,or lacks payment for the filing fee. The re-submittal will require payment
for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source(e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN
options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution
Control Division (APCD)website.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type, etc.).See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Permit Number: 2.1 (A/E 755 AIRS ID Number: 123 / 9F4F /003
.L eav ank unless APCD has ,.;,•a iv,ass,?iieda perralt ar,siAIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Clark 14 Sec HZ; J Clark 14 Sec HZ
Site Location
Site Location:
NWNE Sec 14 T5N R65W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
• Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address2: Jack.Starr@pdce.com
1 Use the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear
on all documents issued by the APCD.Any changes will require additional paperwork.
2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided.
434901
COLORADO
Farm APCD-208 nrdrocat bon Liciii]d LoadIn APEN Re-vision 1 I Mrew° mss
Permit Number: AIRS ID Number: 123 /9F4F/003
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
0 Request coverage under construction permit ❑ Request coverage under General Permit GP07
If General Permit coverage is requested, the General Permit registration fee of$353.13 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
O Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR
• APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Ft Notes: APEN submittal to request Construction Permit coverage for condensate loadout currently permitted under a
Hydrocarbon Liquid Loading General Permit(GP-07);2019 Actual throughput;Emissions calculated using State approved 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: Loading of condensate from storage tanks to tank trucks
Company equipment Identification No. (optional): LOAD-1
For existing sources, operation began on: 4/27/2017
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) 0 Yes 0 No
emissions?
Does this source load gasoline into transport vehicles? 0 Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes ❑ No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual 0 Yes 0 No
average?
Does this source splash fill less than 6,750 bbl of condensate per year? 0 Yes ❑ No
Does this source submerge fill less than 16,308 bbl of condensate per year? ❑ Yes No
COLORADO
Form APCD 208 Hydrocarbon Liquid Loading APEN Revision 07/2020 2 I b&
Permit Number: AIRS ID Number: 123 /9F4F/003
=]cF i.a",2 ApCp <<Fl ",-a i- y:: 7 -=C.1- a':2 ID]
Section 4- Process Equipment Information
Product Loaded: p Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 244,728 bbl/year Actual Volume Loaded: 203,940 bbl/year
This product is loaded from tanks at this facility into: Tank Trucks
(e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor: Average temperature of of
bulk liquid loading:
Molecular weight of
True Vapor Pressure: Psia @ 60 `F lb/lb-mol
displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: bbl/year Actual Volume Loaded: bbl/year
Product Density: lb/ft3
Load Line Volume: ft3/truckload Vapor Recovery Line Volume: ft3/truckload
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.406028/-104.62607
0 Check box if the following information is not applicable to the source because emissions will not be emitted
from a stack. If this is the case, the rest of this section may remain blank.
Operator Discharge Height Above Temp. Flow Rate Velocity
Stack ID No. Ground Level(Feet) ('F) (ACFM) (ft/sec)
Indicate the direction of the stack outlet: (check one)
❑ Upward ❑ Downward ❑ Upward with obstructing raincap
❑ Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width (inches): Interior stack depth(inches):
❑Other(describe):
(COLORADO
Form APCD-208 HyorOcarb`Or Liquid 1.;�3:11t. APEN Revision ",2L):?'.�. 3 x° w
Permit Number: AIRS ID Number: 123 /9F4F/003
[ ea e u., PCD ready 3S.d G ,e;n t o 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.
0 Loading occurs using a vapor balance system: Requested Control Efficiency: %
Used for control of: VOC and HAPs
Rating: MMBtu/hr
Type: Enclosed Combustor Make/Model: 60"Cimarron
Combustion
Device: Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: `F Waste Gas Heat Content: 2593.21 Btu/scf
Constant Pilot Light: ❑✓ Yes 0 No Pilot Burner Rating: MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
Section 7- Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form.
Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑No
If yes, describe the control equipment AND state the requested control efficiencies(report the overall, or
combined, values if multiple emission control methods were identified in Section 6):
Overall Requested
Pollutant Control Equipment Description Control Efficiency
(%reduction in emissions)
PM
Sox
NOx
CO
VOC Enclosed Combustor 95%
HAPs
Other: Enclosed Combustor 95%
0 Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
ID Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
0 Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 2019
Use the following table to report the criteria pollutant emissions from source:
Requested Annual Permit
Emission Factor Actual Annual Emissions
Emission Limit(s)5
Pollutant Source Uncontrolled Controlled Uncontrolled Controlled
Uncontrolled Units ('�'"�Z' Emissions Emissions Emissions Emissions
Basis Mfg.,etc.)
(tons/year) (tons/year) (tons/year) (tons/year)
PM
SOx
NOx 0.1380 lb/MMBtu TCEQ NIA 0 11(DM) N/A 0 13(DM)
CO 0.2755 lb/MMBtu TCEQ N/A 022(DM) N/A 0.26(DM)
VOC 0.2380 lb/bbl State Approved 24.06 1.20 28.88 1 44
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.
��COLORADO
Fort;`.APC. ?CS.. H-,,jlo'`albon E.:ytt J Loa ling APEN Revis„t-.7`/2020 4 ( aril Itralr""onnn `�..n,
Permit Number: AIRS ID Number: 123 /9F4F/003
/003
a U!:1,SC- rc <!,31 , _ ,PIC AIRS Dj
Section 8 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria El Yes 0 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
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions&
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0 0004 Ib/bbi State Approved 84.84(DM) 424(DM)
Toluene 108883
Ethylbenzene 100414
Xylene 1330207
n-Hexane 110543 0.0036 IbIbbl State Approved 736.22 36.81
2,2,4-Trimethylpentane 540841
Other:
6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating,provide
projected emissions.
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
- --- t612 ₹/2 O W
Si ure of Legally Authorized Person (not a vendor or consultant) Date
Jack Starr Senior Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
El Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$216.00 and the General For more information or assistance call:
Permit registration fee of$353.13, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
Air Pollution Control Division OR
APCD-SS-B1 (303)692-3148
4300 Cherry Creek Drive South
Denver, CO 80246-1530 APCD Main Phone Number
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
(COLORADO
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