HomeMy WebLinkAbout20201594.tiff Cp,.��f_„ COLORADO
�.,� +1! Department of Public
COPHF Health b Environment
Weld County - Clerk to the Board
1150 0 St
PO Box 758 RECEIVED
Greeley, CO 80632
April 21, 2020 APR 2 9 2020
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On April 22, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC
Energy, Inc. - Castle 29 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 &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
wpfC-)
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I / ∋
Jared Polis, Governor I Jill Hunsaker Ryan,MPH, Executive Director
Pu b l:c Re v;e c,) cc:PL(irP)HL(1-K) PW(JM(ER/GH la ' 2020-1594
6/T/2-0 o&csKS
5/29/2o
MrM9M Air Pollution Control Division
'''''-r-41 c.M
Notice of a Proposed Project or Activity Warranting Public
CDPHE
Comment
Website Title: PDC Energy, Inc. - Castle 29 sec HZ - Weld County
Notice Period Begins: April 22, 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: Castle 29 sec HZ
production facility
NENW, Section 29, T5N, R64W
Weld County
The proposed project or activity is as follows: operator seeks to permit condensate tanks
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE0818 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Kirk Bear
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
40,„ ._ COLORADO
Deportment of Public
1 I r Health a Environment
Condensate Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Regulation 3 Parts A and B-APEN and Permit Requirements
Source is in the Non-Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(R
Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0!
2. grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions grei
You have indicated that source is in the Non-Attainment Area
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulat
Is the construction date (service date) prior to 12/30/2002 and not modified after 12/31/2002 (See PS Memo 0!
2. grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than 5 TPY or CO emissions greats
Source requires a permit
Colorado Regulation 7,Section XII.C-F
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/ma
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor sta
3. Is this storage tank located upstream of a natural gas processing plant?
Storage tank is subject to Regulation 7,Section XII.C-F
Section XII.C.1 -General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Section XII.D—Emissions Control Requirements
Section XII.E—Monitoring
Section XII.F—Record keeping and Reporting
Colorado Regulation 7,Section XII.G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/ma
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non-stabilized liquids) emissions and have uncontrolled actu
'Storage Tank is not subject to Regulation 7,Section XII.G
Section XII.G.2-Emissions Control Requirements
Section XII.C.1 —General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Section XII.C.2—Emission Estimation Procedures
Colorado Regulation 7,Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well productic
3. Is this condensate storage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions4of this storage tank equal to or greater than 6 tons per year VOC?
Storage tank is subject to Regulation 7,Section XVII, B,C.1&C.3
Section XVII.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3- Recordkeeping Requirements
5. Does the condensate storage tank contain only"stabilized" liauids?
40 CFR, Part 60,Subpart OOOO/OOOOa,Standards of Performance for Crude Oil and Natural Gas Production,Tra
Is this condensate storage vessel located at a facility in the onshore oil and natural gas production segment, na
1. segment of the industry?
2. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) betty
3. Was this condensate storage vessel constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after
4. Are potential VOC emissions)from the individual storage vessel greater than or equal to 6 tons per year?
5. Does this condensate storage vessel meet the definition of"storage vessel"2 per 60.5430/60.5430a?
6. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels in 40 CFR PE
Storage Tank is not subject to NSPS O0OOa
[Note: If a storage vessel is previously determined to be subject to NSPS OOOO/OOOOa due to emissions ab
should remain subject to NSPS OOOO/OOOOa per 60.5365(e)(2)/60.5365a(e)(2)even if potential VOC emissib
40 CFR, Part 63,Subpart MACT HH,Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteri
a. A facility that processes, upgrades or stores hydrocarbon liquids) (63.760(a)(2)); OR
A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enter
b. delivered to a final end user2 (63.760(a)(3))?
2. Is the tank located at a facility that is major3 for HAPs?
3. Does the tank meet the definition of"storage vessel"4 in 63.761?
4. Does the tank meet the definition of"storage vessel with the potential for flash emissions"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart OOOO?
Storage Tank is not subject to MACT HH
Subpart A, General provisions per§63.764(a)Table 2
§63.766- Emissions Control Standards
§63.773- Monitoring
§63.774- Recordkeeping
§63.775- Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non-attainment area. If the t
Disclaimer
This document assists operators with determining applicability of certain requirements of the
Commission regulations. This document is not a rule or regulation, and the analysis it contair
facts and circumstances. This document does not change or substitute for any law, regulatio,
enforceable. In the event of any conflict between the language of this document and the lang
Quality Control Commission regulations, the language of the statute or regulation will control.
"may,""should,"and "can,"is intended to describe APCD interpretations and recommendatioi
intended to describe controlling requirements under the terms of the Clean Air Act and Air Qi
r®y. . COLORADO
440-411 Mr Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0818 Issuance: 1
Date issued:
Issued to: PDC Energy, Inc.
Facility Name: Castle 29 sec HZ
Plant AIRS ID: 123 A07C
Physical Location: NENW quadrant, section29, township 5 north, range 64 west
County: Weld
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
Equipment Description
ID Point Description
TK-1 001 Eight 538 barrel condensate storage tanks Enclosed combustors
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the
specific general terms and conditions included in this document and the following specific terms and
conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. YOU MUST notify the Air Pollution Control Division (Division) no later than fifteen days after
commencement of operation under this permit by submitting a Notice of Startup (NOS)form
to the Division. The Notice of Startup (NOS) form may be downloaded online at
https://www.colorado.gov/pacific/cdphe/air/manage-permit. Failure to notify the Division of
startup of the permitted source is a violation of AQCC Regulation Number 3, Part B, III.G.1 and
can result in the revocation of the permit.
2. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self-certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 9
a . COLORADO
igo Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
4. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self-certification process.
(Regulation Number 3, Part B, Section III.E.)
5. The operator must retain the permit final authorization letter issued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
6. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4.)
Annual Limits:
Facility AIRS Tons per Year Emission
Equipment ID Point PM2.5 NOX VOC CO Type
TK-1 001 0.0 2.1 23.1 4.1 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field office with
site responsibility for Division review.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder and/or
Attachment X" to calculate emissions and show compliance with the limits. The owner or
operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit
prior to the use of any other method of calculating emissions.
8. The emission points in the table below must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Page 2 of 9
MGM• - COLORADO
4 Air Pollution Control Division
CDFHE
`" Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Equipment AIRS Control Device Pollutants
ID Point Controlled
TK-1 001 Enclosed combustor VOC and HAP
PROCESS LIMITATIONS AND RECORDS
9. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Equipment AIRS Process Parameter Annual Limit
ID Point
TK-1 001 Condensate 214,743 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.)I.E.) (State only enforceable)
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by means
of visual observation from the outside of the enclosed combustion device, or by other
means approved by the Division, determine whether it is operating properly. (Regulation
Number 7, Part D, Section I.C.) (State only enforceable)
13. The source is subject to Regulation Number 7, Part D, Section I.G. The operator must comply
with all applicable requirements of Section I.
14. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device
Page 3 of 9
a . . COLORADO
' - Air Pollution Control Division
CDPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
is used to control emissions of volatile organic compounds to comply with Section II, it must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual
observation from the outside of the enclosed flare or combustion device, or by other convenient
means approved by the Division, determine whether it is operating properly. This flare must be
equipped with an operational auto-igniter according to the schedule in Regulation Number 7,
Part D, Section II.B.2.d.
15. 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.
16. 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.
17. The storage tanks covered by this permit are subject to the storage tank measurement system
requirements of Regulation Number 7, Part D, Section II.C.4.
18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing plant
in Colorado must submit a single annual report that includes actual emissions and specified
information in the Division-approved report format. The information included in the annual
report must be in accordance with the general reporting requirements of Regulation Number 7,
Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or
operators must maintain the information according to Regulation Number 7, Part D, Section
V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING a MAINTENANCE REQUIREMENTS
19. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (OI:tM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&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
20. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen-minute period during normal
operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23)
Page 4 of 9
tiM,M-CCOLORADO
'14I , Air Pollution Control Division
Department of Public Health b€nvironment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
22. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
23. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self-certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self-Certify for Final Authorization section of this permit.
Page 5 of 9
hak11 COLORADO
map4ualkiti Air Pollution Control Division
COPHE
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
24. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
25. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
26. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self-certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
27. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
28. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Kirk Bear
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc.
Page 6 of 9
_ COLORADO
Air Pollution Control Division
CDAHE
Department of Public Health Er 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 2255 113
Toluene 108883 2792 140
Ethylbenzene 100414 86 5
001
Xylenes 1330207 1053 53
n-Hexane 110543 20509 1026
224 TMP 540841 34 2
Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
Uncontrolled
CAS # Pollutant Emission Factors Source
lb/bbl
NOx 0.1380 lb/MM Btu TCEQ
CO 0.2755 lb/MM Btu TCEQ
VOC 4.3027 promax
Page 7 of 9
»gib• - COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Uncontrolled
CAS # Pollutant Emission Factors Source
lb/bbl
71432 Benzene 0.0105 promax
108883 Toluene 0.0130 promax
100414 Ethylbenzene 0.0004 promax
1330207 Xylene 0.0049 promax
110543 n-Hexane 0.0955 promax
540841 224 TMP 0.0002 promax
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This facility is classified as follows:
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, CO, NOx, HAP
PSD Synthetic Minor Source of: VOC
NANSR Synthetic Minor Source of: VOC, NOx
9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS 60.1-End Subpart A - Subpart UUUU
NSPS Part 60, Appendixes Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
Page 8 of 9
C,..
.Ms'f.M- COLORADO
44"Y°41° Air Pollution Control Division
CDPHE
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
MACT 63.1-63.599 Subpart A - Subpart Z
MACT 63.600-63.1199 Subpart AA - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 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
3 tog
Condensate Storage Tank(s) APEN
• ;., CDPHE
CO Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. An application with missing information may be determined incomplete and may be returned or result in
longer application processing times. You may be charged an additional APEN fee if the APEN is filled out
incorrectly or is missing information and requires re-submittal.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.Qov/pacific/cdphe/air-permits.
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a 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: /9 WE g I g AIRS ID Number: I Z, 1Ay. 1C /CO I
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 1 -Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Castle 29 sec HZ
Site Location
Site Location:
NENW Sec 29 T5N R64W County: Weld
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address2: Jack.Starr@pdce.coin
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.
Lit l(4LilC
COLORADO
Form APCD-205- Condensate Storage Tank(s)APEN- Revision 7/2018 1 I AV Noah=1st
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly-reported emission source
❑✓ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
0 GP01 0 GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment 0 Change company name3
O Change permit limit 0 Transfer of ownership' 0 Other(describe below)
-OR
▪ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info Et Notes: Initial permit request for condensate storage tanks at a new facility
3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted.
4 For transfer of ownership,a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 05/13/2019
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year
Storage tank(s) located at: ❑✓ Exploration Ft Production (EEO)site ❑ Midstream or Downstream (non EEtP)site
Will this equipment be operated in any NAAQS nonattainment area? ✓❑ Yes 0 No
Are Flash Emissions anticipated from these storage tanks? ❑r Yes ❑ No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? p Yes 0 No
If"yes", identify the stock tank gas-to-oil ratio: 0.008015 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) 0 Yes 0 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 0Yes ❑ No
emissions≥6 ton/yr(per storage tank)?
wricoLoRAD0
Form APCD-205 - Condensate Storage Tank(s)APEN - Revision 7/2018 2 I AY 3°, Z,g,
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 178,952 214,743
From what year is the actual annual amount? Projected
Average API gravity of sales oil: 50.5 degrees RVP of sales oil: 7.3
Tank design: ❑✓ Fixed roof O Internal floating roof ❑ 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 8 4,304 4/2018 5/2019
Wells Serviced by this Storage Tank or Tank Battery6(EEP Sites Only)
API Number Name of Well Newly Reported Well
05 -123 -46284 Castle 1N ✓❑
05 -123 -46291 Castle 2N ✓❑
05 -123 -46294 Castle 3N ❑✓
05 - 123 -46292 Castle 4N 0
O
5 Requested values will become permit limitations. Requested limit(s)should consider future growth.
6 The El-tP Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.37615 /-104.5761
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level (feet) (°F) (ACFM) (ft/sec)
N/A
Indicate the direction of the stack outlet: (check one)
❑Upward 0 Downward 0 Upward with obstructing raincap
❑Horizontal 0 Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches):
0 Square/rectangle Interior stack width(inches): Interior stack depth(inches):
0 Other(describe):
COLORADO
Form APCD-205-Condensate Storage Tank(s)APEN - Revision 7/2018 3 ""° "`°'�°nta;12,0 nmvn
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Pollutants Controlled:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
❑ Combustion
Device:
Pollutants Controlled:
Rating:
Type:
VOC and HAPs
MMBtu/hr
l 4 x Cimarron 48" & 1 x Cimarron 60"
Enclosed Combustors Make/Mode:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Constant Pilot Light: 0 Yes D No Pilot Burner Rating:
Waste Gas Heat Content:
2,551
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (ECtP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 28.9 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
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Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall(or combined)control efficiency(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction in emissions)
VOC Enclosed Combustor 95%
NOx
CO
HAPs Enclosed Combustor 95%
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Emission Factor? Actual Annual Emissions Requested Annual Permit
Emission Limit(s)5
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis e Units (AP-42, Emissions Emissions8 Emissions Emissions
Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year)
VOC 4.3027 lb/bbl ProMax 384.99 19.25 461.99 23.10
NOx 0.1380 Ib/MMBtu TCEQ N/A 1.71 N/A 2.05
CO 0.2755 Ib/MMBtu TCEQ N/A 3.42 N/A 4.10
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor? Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions8
Number Basis Mfg.etc) Pounds/ ear
g (Pounds/year)) (Pounds/year)
Benzene 71432 0.0105 lb/bbl ProMax 1,872.90 93.65
Toluene 108883 0.0130 lb/bbl ProMax 2,329.54 116.48
Ethylbenzene 100414 0.0004 lb/bbl ProMax 70.92(DM) 3.55(DM)
Xylene 1330207 0.0049 lb/bbl ProMax 873.58 43.68
n-Hexane 110543 0.0955 lb/bbl ProMax 17,087.90 854.40
2,2,4- 540841 1 .54E-04 lb/bbl ProMax 27.64 (DM) 1 .38 (DM)
Trimethylpentane
5 Requested values will become permit limitations. Requested timit(s)should consider future growth.
7 Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave
blank.
w COLORADO
Form APCD-205- Condensate Storage Tank(s)APEN - Revision 7/2018 5 I • 'v HOaI 7.6[nWnvuy¢ril
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 9 -Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Uat@
Sign:t re of Legally Authorized Person (not a vendor or consultant)
Jack Starr Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
❑✓ Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment,change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148
Air Pollution Control Division
APCD-SS-B1 APCD Main Phone Number
4300 Cherry Creek Drive South (303)692-3150
Denver, CO 80246-1530
Make check payable to: Or visit the APCD website at:
Colorado Department of Public Health and Environment https://www.colorado.gov/cdphe/apcd
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Form APCD-205 - Condensate Storage Tank(s)APEN - Revision 7/2018 6 I ^`°:"`°"`NpxtlhtF•i onrtien�
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