HomeMy WebLinkAbout20203732.tiff M,;.y COLORADO
Department of Public RECEIVED
coPt1E Health b Environment
DEC 0 7 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
11500 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 - Dunn 7 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
or.-dam.,
4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I 4.1r,/ .-'*_:A*,%,,,
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director ,,# .,.i,.);
Pub 1 c Re v ;e eJ cc:Pt_(TP),H1.(ps/rg.),Pw(2t4/ERicH/c K), 2020-3732
O6(SM)
12/23/20 12.iis120
MtMdM Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
41,,,,,::
tDPHE
Cht 1:4
Comment
Website Title: PDC Energy, Inc - Dunn 7 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: Dunn 7 Sec HZ
Well Production Facility
SWSW quadrant of Section 7, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: PDC Energy, Inc wishes to reduce requested permitted
emissions by reducing requested condensate throughput.
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 17WE0970 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Diego Chimendes
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
. COLORADO
1 G°°"` Department of Public
Health 6 Environment
C..
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: 1 7WE0970 Issuance: 3
Date issued: XX/XX/XXXX
Issued to: PDC Energy, Inc.
Facility Name: Dunn 7 Sec HZ
Plant AIRS ID: 123/1446
Physical Location: SWSW SEC 7 T5N R64W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Equipment Description
ID Point Description
Twenty-two (22) 538 barrel fixed roof
TK-1 001 liquid manifold storage vessels used to Enclosed Combustors
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-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
Page 1 of 9
N:,». 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
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. The operator must 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, VOC CO Type
TK-1 001 --- 2.0 17.8 42 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Compliance with the annual limits for criteria pollutants must be determined on a rolling twelve
(12) month total. By the end of each month a new twelve month total is calculated based on
the previous twelve months' data. The permit holder must calculate actual emissions each
month and keep a compliance record on site or at a local field office with site responsibility for
Division review.
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
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
Page 2 of 9
.4,1 COLORADO
4 4440 Mr Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility AIRS Process Process Parameter Annual Limit
Equipment ID Point
01 Condensate Throughput 442,260 barrels
TK-1 001 02 Combustion of pilot 2.0 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
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
Page 3 of 9
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 a MAINTENANCE REQUIREMENTS
15. 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
the OI:tM plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16: This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
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:
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 (NO.) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
Page 4 of 9
C «IT COLORADO
0 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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
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.
Page 5 of 9
C •» ; COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 April 19, 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
C _r COLORADO
41- NeW
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: 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 1804 90
Toluene 108883 2462 123
Ethylbenzene 100414 93 5
001 Xylenes 1330207 1103 55
n-Hexane 110543 13781 689
2,2,4-
540841 94 5
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 8.770x1O3 8.770x10"3 TNRCC and Promax
CO 1.751x10-2 1.751 x1O2 TNRCC and Promax
VOC 1.6122 8.0601x1 0-1 Promax
Page 7 of 9
j r ;r COLORADO
44.41.
Nate 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 4.079x10-3 2.040x10-4 Promax
108883 Toluene 5.567x10-3 2.783x10"4 Promax
1330207 Xylene 2.495x10-3 1.247x10"4 Promax
110543 n-Hexane 3.116x10-2 1.558x10"3 Promax
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 Dunn 7L-301 well
on 08/24/2017. 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 2298.7 Btu/scf, molecular weight of 41.1 lb/lbmole,
a standard molar volume of 379.41 scf/lb-mole, and a VOC mol%of 53.8%.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 fifteen (15) combustors used to control emissions from the
condensate storage vessels. As a result, the total pilot light gas fuel flow is 234 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:
Applicable Status
Requirement
Page 8 of 9
Cv:t. COLORADO
Air Pollution Control Division
.43i467 Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Operating Permit Synthetic Minor Source of: VOC. True Minor Source of CO, NOx
and HAPs.
PSD True Minor Source of: CO Et NOx
NANSR Synthetic Minor Source of: VOC.
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.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
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 it Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details For Division Use Only
Review Engineer: Diego Chimendes
Package#: `427150.
Received Date: 7/31/2020
Review Start Date: P11/3/2020
Section 01-Facility Information
Company Name: PDC Energy,Inc. Quadrant Section Township Range _
County AIRS ID: 123 SWSW 7 ;5N 64..
Plant AIRS ID: 1446
Facility Name: Dunn 7 Sec HZ
Physical
Address/Location: SWSW quadrant of Section 7,Township 5N,Range 64W
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment?OR&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
001 Storage Tank TK-1 Yes 17WE0970 3 Yes Modification
Section 03-Description of Project
PDC Energy,Inc.(PDC)submitted an application requesting modification of permit 17WE0970.PDC wishes to reduce requested permitted emissions by reducing
requested condensate throughput.
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 II.B: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
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: 502 NOx CO VOC PM2.5 PM10 TSP NAPS
Prevention of Significant Deterioration(P5D) —
Title V Operating Permits(OP) ✓ ❑ ❑
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) _
Title V Operating Permits(OP) Ill LI
Non-Attainment New Source Review(NANSR)
Storage Tank(s)Emissions Inventory
Section 01-Administrative Information
Facility AIRs ID: 123 1446 001
Facility
County Plant Point
Section 02-Equipment Description Details
Storage Tank Liquid ;Condensate
Detailed Emissions Unit Twenty-two(22)538 barrel fixed roof liquid manifold storage vessels used to store condensate.
Description:
Emission Control Device Fourteen(14)Cimarron 48"&one(1)Cimarron 60"enclosed combustors..
Description:
Requested Overall VOC&HAP Control Efficiency%: 95.0
Limited ProcessParameter V' ;v "?j j"+t '
Section 03-Processing Rate Information for Emissions Estimates
Primary Emissions-Storage Tank(s)
Actual Throughput= 368,549.0 Barrels(bbl)per year
'Requested Permit Limit Throughput= 442,260.0 Barrels(bbl)per year Requested Monthly Throughput= 37561.8 Barrels(kb))per month
Potential to Emit(PTE)Condensate Throughput= 442,260.0 Barrels(bbl)per year
Secondary Emissions-Combustion Device(s)
Heat content of waste gas= 2298.7 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced= scf/hbl
Molecular Weight= 41.1 Ib/Ibmol
VOC cool%= 53.82%
Molar Volume= 379.4 scf/Ihmol
Actual heat content of waste gas routed to combustion device= 23,420.2 MMBTU per year
Requested heat content of waste gas routed to combustion device= 28,104.3 MMBTU per year
Potential to Emit)PTE)heat ocrstent of waste gas routed to combustion device= 28,104.3 MMBTU per year - ,-
Control Device
Pilot Fuel Use Rate: "s^r"w Wv-s 33'.scfh 2.0 MMscf/yr
Pilot Fuel Gas Heating Value: ;_. f 1136'.Btu/scf 2328.6 MMBTU/yr
Section 04-Emissions Factors&Methodologies -
Will this storage tank emit flash emissions? r ,
Emission Factors Condensate Tank
Uncontrolled Controlled
Pollutant (lb/bbl) (lb/bbl) Emission Factor Source
(Condensate (Condensate
Throughput) Throughput)
VOC 1.6122E+00 8.0610E-02 Site Specific By.(includes flash)
Benzene 4.079E-03 2.040E-04 _Site Suecific E.F.(includes Rash)
Toluene 5.567E-03 2.783E-04 Site Specific E.F.(includes flash)
Ethylbenzene 2.108E-04 1.054E-05 Site Specific E.F.(includes flash)
Xylene 2.495E-03 1.247E-04 Site Specific E.F.{includes flash)
n-Hexane 3.116E-02 1.558E-03 Site Specific E.F.(includes flash)
2247MP 2.129E-04 1.065E-05 Site Specific E.F.:(includes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant (Ib/MMBtu) (Ib/bbl) Emission Factor Source
(waste heat (Condensate
c amhusted) Throughput)
PM10 0.0075 4.735E-04 AP-42 Table 1.4-2(PM10/PM2.5)
PM2.5 :':0.0075 4.735E-04 _AP 42 Table 1.4-2(PMSO/PM 2.5)
5Ox 0.0006 3.738E-0S Other-Expia in
NOx 0.1380 8.770E-03 TNRCC Flare Emissions Guidance.(Nob)
CO 0.2755 1.751E-02 TNRCC Flare Emissions Guidance(CO).
Pilot Light Emissions
Uncontrolled Uncontrolled
Pollutant (lb/MMBtu) Ilh/MMscf) Emission Factor Source
(Pilot Gas Heat (Pilot Gas •
Combusted( Throughput)
PM10 0.0075 8.5 AP-42 Table 1.4-2(PM10/PM 2.5)
PM2.5 ..:.0.0075 8.5 AP-42 Table 1.4-2(PM10/PM2.5)
50x 0.0006 0.7 AP-42 Table 1.4-2(SOo(
NOx .. :0.0680 77.2 AP 42 Chapter 13.5 Industrial Flares(N0s)
VOC 0.0054 6.1 AP-42Tabie 1.4-2(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) (Ihs/month)
PM10 0.1 0.1 - 0.1 0.1 0.1 19.3
PM2.5 0.1 0.1 0.1 0.1 0.1 19.3
5Ox 0.0 0.0 0.0 '0.0 0.0 1.5
NOx 2.02 1170 1.70 2.02 2.02 342.8
VOC 356.51 297.09 14.86 356.51 17.83 3028.9
CO 4.23 3.59 3.59 4.23 4.23 718.9
3 of 9 K:\PA\2017\17WE0970.CP3
Storage Tank(s)Emissions Inventory -
Potential to Emit Actual Emissions Requested Permit Limits
Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled
(Ibs/year) (Ibs/year) (lbs/year) (Ibs/year) (Ibs/year)
Benzene 1804 1503 75 1804 90
Toluene 2462 2052 103 2462 123
Ethylbenzene 93 78 4 93 5
Xylene 1103 920 46 1103 55
n-Hexane 13781 11484 574 13781 689
224 IMP 94 78 4 94 5
•
4 of 9 K:\PA\2017\17WE0970.CP3
Storage Tark(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 I.C-F
Regulation 7,Part D,Section I.S,C Storage Tank is not subject to Regulation 7,Section I.G
Regulation 7,Part D,Section 11.0,C.1,C.3 Storage tank is subject to Regulation 7,Part D,Section II,B,Cl&C.3
Regulation 7,Part D,Section II.C.2 Storage tank is subject to Regulation 7,Part D,Section II.C.2
Regulation 7,Part D,Section Il.C.4.a.(i) Storage Tank is not subject to Regulation 7,Part D,Section II.C.4.a(i)
Regulation 7,Part.D,Section II.C.4.a.)ii) Storage Tank is not subject to Regulation 7,Part D,Section II.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 00000
Regulation 8,Part E,MACT Subpart Fill Storage Tank is not subject to MACT 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?
Ryes,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 attual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy?
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?
Ryes and if there are flash emissions,are the emissions factors based on a pressurized liquid sample drawn at the facility being
permitted(for produced water tanks,a 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 "
date.However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to use an :
older site-specific sample.
If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03.
N
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 Dunn 7L-301
well.This well is one of the eleven(11)wells drilled at this facility and there were no significant changes to the facility since the development of the emissions factors;Asa result,the permit will not require initial
testing in order to obtain a new site specific sample.It should be noted that the sample includes sample probe temperature and pressure in conjunction with gauge pressure and temperature.-
• e_-I 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)}x[2000(lb/ton)]-MW(lb/Ibmo1)*[379,41(stf/Ibmo1)]*[1/VOC mot°A]s[Heat Content(Btu/s f)]x[1MMBtu/(1000,000 Btu)].
ou.T-.; The values used in the equation were obtained from a Pro Max simulation used to calculate emissions and develop emission facto.The values used are as follow:)i)Molecular weight:41.11b/Ib-mol,(ii)VOC mot%:
-' 53.8%,(iii)Heat Content:229075tu/scf. - -
, 3.Pilot Light Emissions Calculations:Operator assumed pilot fuel to have the same conditions of field gas which is with the plant design provide by o Aerator.The permit will not contain initial or periodic
° s' opacity testing for the enclosed combustors)because the O&M plan approved for this sour.requires weekly visible emissionsgbservations of the enclosed combustor(s).Athroughput limit is included in the permit
: far pilot combustion Emission factors and calculationmethods for pilot light combustion emissions are also included in shotes 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 danty is important for accuratelyquantrfying actual emissionsat this facility.
4.Self-certification was submitted by operator on 10/16/2514 Division approved self-certification on 10/08/2020.
S.Permit draft sent to operator for review on 11/18/2020:Operator expressed they had:no comments on 11/30/2020.
Section 09-SCC Coding and Emissions Factors(For Inventory Use Only)
Uncontrolled
Emissions
. AIRS Point Process SCC Code Pollutant Factor Control% Units
001 01 _ 43:fixed Roof Tank,Condensate,working,breath ng+nashmg tosses PM10 0.01 -0 lb/1,000 gallons Condensate throughput
PM2.5 0.01 0 lb/1,000 gallons Condensate throughput
50x BREFI 0 Ih/1,000 gallohs Condensate throughput
NOx 0.22 0 lb/1,000 gallons Condensate throughput
VOC 38.39 95 lb/1,000 gallons Condensate throughput
CO 0.46 0 lb/1,000 gallons Condensate throughput
Benzene 0.10 95 lb/1,000 gallons Condensate throughput
Toluene 0.13 95 lb/1,000 gallons Condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons Condensate throughput
Xylene 0.06 95 lb/1,000 gallons Condensate throughput
n-Hexane 0.74 95 lb/1,000 gallons Condensate throughput
224 TMP 8.01 95 lb/1,000 gallons Condensate throughput
5 of9 K:\PA\2017\17WE0970.CP3
Storage Tank Regulatory Analysis Worksheet
The regulatory requirements below are determined based on requested emissions.
Colorado Reaulation 3 Parts s andB-APEN and Permit Requirements
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater then 2 TPY(Regulation 3,Part A,Section11.01.a)? Source Requires an APEN.Beta
2. Is the tructl date rvice d )priorto 12/30/2002 and not modified after 12/31/2002(See PS Memo 0501 Defircons112 and1.14 and Section 2 for additional guidance on grandfather appliabilityl7 Go tonext question
3. Are total f City uncontrolled VOC emissions greater thanS TPY,NOx g ater than to TPY or CO emissions greater than LOTPY(Regulation 3,Part B Section 11.1.3)? Source Requires a permit
I-o
NON-ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TP'(Regulation 3,Part A,Section ll.O.1.a)? s,'r'.3'5.xEY°?Source Requires an APEN.Gots
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)? Go to next question
3. Are total facility uncontrolled VOC emissions greater than 2TPY,NOx greater than 5TPY or CO emissions greater than OOTPY(Regulation 3,Part B,Section 11.1.2)? ,. i< Source Requires a permit
ISau
Colorado Regulation 7.Part 0.Section I.C-F&G
1. Is this storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part 0,Section 01.11? Km, Continue-You have indicated th
2. [stills storage tank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located M or upstream of a natural gas processing plant(Regulation 7,Part 1,Section 1.5.117 Yes Continue-You have Indicated th
3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part 0,Section 1.5)? Storage Tank Is not subject to Rs
4. Does this storagetank contain condensate? Vvs
5. Does thisstoragetank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation 7,part D,Section 1.5.217 -
6. Are uncontrolled actual emissions of this storage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part 0,Section l.D.3.aIRll? WSW
Part 0,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage
Part O,Section I.G2—Emission Estimation Procedures
Part D,Section 1.0—Emissions Control Requirements
Part 0,Section I.E—Monitoring
Part D,Section I.P—Recordkeeping and Reporting
Kmrase nun,:Is Jim subject to _.-,..n 7,Sortie',I.5
Part D,Section I.G.2.Emissions Control Requirements
Part D,Section I.C.1.e and b—General Requirements far Air Pollution Control Equipment—Prevention of Leakage
Colorado Regulation 7,Part O.Section ll _
1. Is this storage tank located eta transmission/storage facility? _Continue-You have Indicated th
2. Isthis storagetanks located at an oil and gas exploration and production operation,well production facility',natural gas compressor station or Natural gas processing plans°lRegulation 7,Part D,Section 11.117 Go to the next question-You ha
3. Does this storage tank have fixed roof(Regulation 7,Part❑,Section ll.A.20)7 ':Go to the next question
4. Are uncontrolled actual emissionsf th rage tank equal to or greater than 2 tons per year VOC(Regulation 7,Part D,Section ll.C.t.c)7 'flsnijA715,j Source is subject to parts of Regi
Iu rank.s. un.1.F.r 3L1
Part D,Section ll.B—General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Part D,Section II.C.1-Emissions Control and Monitoring Provisions
Part D,Section II.0.3-Recordkeeping Requirements
5 Dees thestorag k contain only1stabil,ednliquids(Regulation 7,Part I,Section II.C.2.6)? s; 'Source Is subject to all provis om
Part 0,.Section llC2 Captured M R ing for Storage Tanks fitted with Air Pollution Control Equipment
Is the controlled storage tank l d at a wellproduction facility,natural gas compressor station,or natural gas processing plant constructed on car after May 1,2020or located at a facilitythat was modified on or after May 1,2020,such
6, that an addition.controlled storage vessel's constructed to receive an anticipated increase through put of hydrocarbon liquids or produced water(Repletion 7,Part D,Seaton II.C.4.a.II? ..o ,. Storage Tan k's not subject to Re
Is the contralled storage tank1 d at a wellpod facility,natural gas compressorstaton,or naturalgas processing plant constructed an or after January 1,2021 or located at a facility that was modified on or after January 1, yj,j1
7. 2021,such that an additon.controlled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Repletion 7,Part 0,Section Il.C4a Id?
40 CFR Part605 b Kb,Standards ofPerformance f Volatile Organic Liquid Storage Vessels
1 the individual storage vessel capacityg t than or equalt 75 cub (m)['4?2 BBls](40 CFR 60.110blall? Ye, Go to the next question
2. Does the storage vessel meet the following exemption in 60.111b(d)(41? Storage Tank is not subject SOPS
a.Does the vessel has a design capacity less than or equal to 1,589.874 m°['10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined in 50.111b?
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.21 after-July 23,1984(40 CFR60.110b(a))?
4. Does the tank meet the definition of"storage vessel"'in 60.111b7 -
5. Dees the storage vessel store a"volatile organic squid(VOL)"'as defined In 60.1116?
G. Does the storage vessel meet any one of the following additional exemptions: .-.
a.tsthestoage vessel a pressure vessel designed to operate in excess of 204.9 kPa['29.7psi]and without emissions to the atmosphere l60.1106fdl(2))7;or --
b.The design capacity is greater than or equal to 151 m°('950 BBL]and stores a liquid with a maximum true vapor pressure'less than 3.5 kPa(60.11ob(b))7;or -
c.The design capacity is greaterthan or equal to 75 M'[^472 BBL]but less than 151 m5[-950 BBL]and stores a liquid with a maximum true vapor pressure°less than 1_5.0 kpa(60.110b(b)l7
7. Does the storage tank meet either one of the following exemptions from control requirements:
a.The design capacity is greater than or equal to 151 m'[-950 BBL]and stores a liquid with a maximum true vapor pressure greater than.or equal to 3.5 kPa but less than 5.2 kPa7;or
b.The design capacity is greater than or equal to 750(-472 BBL]but lessthan 151 m'["950 BBL]and stores a liquid with a maximum tree vapor pressure greater than or equalto.15.0 kPa but less than 27.6(JIM? ,
N,anagr'ianks not sublort to y5P31th
40 CFR,Part Mk Subpart 0000/0000a,Standards of Performance for Crude Wand Natural Gas Produetian,Tmrumission 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 th
2. Was this storage vessel constructed,reconstructed,an modified(see definitions 40CFR,60.2)between August 23,2011 and September 18,20157 Sig 7.1=Storage Tank's notsubject NSPS
3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,60.2)after September 18,20157 1'iFSW2it."I/(i Go to the next question
4. Are potential VOC emissions'from the individual storage vessel greater than or equal to stone per year? N44ihy 'Storage Tank is nat subject NSPS
vessel g / /i'lh.Ko
5 Does this storage mee[the definition of"storage per 5430 60 60 5430a7 7s�S. Is the storage vessel subject to and controlled in accordance with requirements for storage vessels In 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Subpart 1417 Rat tS'
I_ttarage Mani:=s„vas tie,to Ti5P5 0000
(Nate:If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tans per year V0C onthe applicability determination date,[(should remain subject to NSPS 0000/0000a per
60.5365(e)l2)/60.5365a(el(2)even If potential 000 emissions drop below 6 tons per year]
40 CFR,Part63,Subpart MALT 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 criteria: Vet Continue-You have indicated th
a.Afacility that processes,upgrades or stores hydrocarbon liquids'(63.760(a)(2));OR
b.Afacility that processes,upgrades or stores natural gas priorto the point at which natural gas enters the natural gas transmission and storage source category or is delivered to aline(end user'(63.7601a1(3)l?
2. Is the tank located at a facility that is major'for HAPs? /4rt4>t »';Storage Tank 6 not subject MAC
3. Does the tank meet the definition of"storage vessel""in 63.761? awe
4. Does the tank meet the definition of"storage vessel with the potential forflash emhsions"s per 63.761?
S. Is the tank subject to control requirements under 40 CFR Part 60,Subpar-UM or Subpart 00007 ,Nftg'jf
Subparts,General provisions per 863.764(a)Table 2
§63.766-Emissions Control Standards
§63.773-Monitoring
§63.774-Recordkeeping
563.775-Reporting
RACT Review
RACT review is required If Regulation]does not apply AND if the tank is in the non-attainment area.It the tank meets both criteria,then review 5701 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,end 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 law,regulation,
r any other legally hinding.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 neconuttnd,""may,"'should,"and"can."is intended to
describe APCD interpretations and recommendations.Mandatory terminology such as'Must°and"required"are intended to describe controlling requirements undergo terms of the Clean Air Act and Air
Quality+Conttol 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 11/30/2020
Plant AIRS ID 1446 Ozone Status Non-Attainment
Facility Name Dunn 7 Sec HZ
EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year)
POINT PERMIT Description PM10 PM2.5 H25 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 0.9 0.9 0.0 0.0 98.2 1,562.2 _ 0.3 _87.0 41.3 _ 1.0 1.0 0.0 _ 0.0 19.5 84.3 0.3 41.5 3.1
Previous Permitted Facilit total 0.7 0.7 0.0 0.0 95.6 1,562.1 0.0 84.8 41.2 0.7 0.7 0.0 0.0 16.0 83.7 0.0 37.6 3.1
001 17WE0970 Twenty-two 538 bbl condensate storage 0.3 2.0 356.5 4.2 9.7 0.3 0.3 2.0 17.8 4.2 0.5 Point updaled on 11)042020-requested lower
tank. emission limits.DC 11/0412020
002 18WE0682 One(1)10 vessel tank and One(1)single 1.2 0.2 1.2 0.2 No Change
vessel tank for Produced water
003 GP07 Condensate loadout 0.8 198.4 1.6 3.4 0.8 10.0 1.6 0.2 No Change
004`- GPO2.CN "51 RICE GM Vortec 5.7L,4SRB,88 HP _ ..
q(site rated)SN:16BX1M102110115 `
005 GP02.CN SI RICE GM Vortec 5,71,4SRB,88 HP
(site rated)SN:BX1M105190099
006 GP02.CN SI RICE GM Vortec 5.71-,4SRB,6B HP 0.0 - 0.0 Cancellation received on 07/16/2020.Equipment
(site toted)ON 13218960 removed.
007 GP02.CN SI RICE GM Vortec 5 7L,4SRB,88 HP :. 0.0 0.0 Cancellation re ceived on 07/16/2020.Equipment
(site rated)SN-10BX1M105130029 removed,
008 GP02 SI RICE GM Vortec 5.7L;4SRB 88 HP 0.0
(site rated)SN;27511435 Cancelled 7/1/2019,no longer exists
009 GP02.CN .SI RICE GM Vortec 5.7L,4SRB 88 HP - 0.0 0:0 Cancellation received on 07/16/2020.Equipment
(site rated)SN:10CHMM503060087 removed.
010 GP02 SI RICE Zenith ZPP644,4SRB,94 HP(site 0.1 0.1 8.6 0.1 14.4 0.1 0.1 0.1 - 1.9 0.2 3.0 0.1 No Change
rated)SN:614204
011 GP02.CN I' SI RICE Zenith ZPP644,4SRB,94 HP(site
rated)SN:.614207
012 GP02.CN SI RICE Caterpillar G3406 TA,263 HP
(site rated)SN:4FD04590
013 GP02.CN SI RICE Caterpillar G3406TA,276 HP,SN:
4FD00382
014 GP02 SI RICE Caterpillar G3406TA,276 HP,SN
CRE00210 - >, Cancelled 1/31/2019,no longer exists
015 GP02 GM Vortec 5,7L sn:13219369 11.8 0.6 y 9.3 0.1 0.9 0.6 1.7 0.1 No Change
016 GP02.CN SI RICE GM Vortec 5.71,4SRB 86 hp ' 0.0 OD Cancellation received on 07/16/2020.Equipment
removed
017 GP02 CAT G3406TA 276 hp SN.CRE00211 ' _ Cancelled 1/31/2019,no longer exists
018 GP02 Red River GM 9.OL 136hp SN:296106 0.1 0.1 16.0 3.5 14.6 0.2 0.1 0.1 0.6 0.9 0.5 0.2 No Change
019 GP02.CN Red River GM 9.01 136hp SN 296108` 0.0 0.0 Cancellation received on 07/16/2020.Equipment
removed.
XA External Combustion Sources 0.2 0.2 2.6 0.1 2.2 0.0 _ 0.2 0.2 2.6 0.1 2.2 0.0 Insignificant Source
XA Fugitives _ 0.3 0.0 0.3 0.0 Insignificant Source
FACILITY TOTAL 0.7 0.4 0.0 0.0 41.9 560.4 0.3 46.3 13.7 0.7 0.7 0.0 0.0 8.9 30.8 0.3 13.2 1.3 VOC:Syn Minor(NANSR and OP)
NOx:True Minor(NANSR and OP)
CO:True Minor(OP),True Minor(PSD)
HAPS: Minor
7777:Area
Permitted Facility Total 0.5 0.2 0.0 0.0 _39.3_ 560.3 0.0 44.1 13.7 0.5 0.5 0.0 0.0 6.3 30.7 0,0 11.0 1.3 Excludes units exempt from permits/APENs
(A)Change in Permitted Emissions -0.2 -0.2 0.0 0.0 -9.7 -53.0 0.0 -26.6 Puhcom 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 based on change in
emissions.
Total VOC Facility Emissions(point and fugitive) 31.1 Facility is eligible for GP02 because CO<90 tpy&
NoxNOC<45 tpy.
(A)Change in Total Permitted VOC emissions(point and fugitive) -53.0 Project emissions less than 25 tpy
Note 1
Note 2
Page B of 9 Printed 11/30/2020
COLORADO DEPARTMENT OF PUBLIC HUL.AND ENVIRONMENT AIR POLL.06 DIVISION
FACILITY 513155.65.37136,11A34
Cornea.Name PDC Enemy
County AIRS In 123
P13,6563 ID 1015
FacllnvlName DU.5*c HS
Emissions-uncontrolled 1100 per Year
NTIPER I:M.9920n n•mer•n85PI8IaNApple.AeApple. Benzene Toluene coneemens 0,90,990A,e0 0H92a00 me..9 u2* 04s .131
Pravlo,16 FACILITY TO AL 06 01 01 39 48 03 21 23 01 02 on 00 413
601 Inv®]0 T.wn101005020010002a storage 9.7
002 1ewE0002 Dee 111100cese11mkme02(11 .2.1. 1 5.5 .,a 02 ter ans arms oaeaul A. 63 o 39
009 GPo2CS SI RIGEGM Vorte05.R,!211, HP' 0.0
lslreiabi110.113102110115910.113102110115I5 O. GP3zcI 9Rt9EGM001025 1 5 SOR.06 HP 00
335.9611
006 CPo23N .PIG000Vkchri vSRe BHP
sA01¢10019N'.1921053 OA
P02GN`r (sro raletl 3N1O6.S'A]M14 1 HP. 00,
GM sn,952B60HP M«teo
V
00
OOB GPM. SI RIGSGM Va10 00 153306 88 HP 0.0
1s lerel�l99:1aeHMM1
010 31702
011 GP02CT9. x2 zm M2PPo19,95.5,09 HP 0.0
2100,2 102 33 012 0P02 ON 9361.4.045TA;263 HP 00
rmler79361.4.04530
013 GPo2CN ..3111,23909TA.2Y6HP, 00
x93.0302
019 GPo2 SIRIGEOMe 339051
SN'CRE0021011ar
A 276 HP 0
01
016 GPo2CN SIR CE GM Vor.VILASP.8 hp: 00
012 OP. 3ATGa96TA 2 i6 FP SN CRE002 H 00
010 0P00014 06.0731031510513513,10 296100XA Externs! 00
XA Fu9inves�Ie4en Sweces 1_9 124 12. 121 IiO 00
TA Stpy( 6.a 0.6 0.0 1A t.a 0.1 6.5 X9T 6.6 0.6 0.0 0.0 19.1 ToMIReportable=aO HAPa where uncennolled emlulons e du min imus values
Emissi ons 0040 coptr0ls fibs ea s par Meer
POINTIPERMIT emApeon Tawa...,�.,.eeae„,.Acrel0ln Ben.. Toluene eNreeee,.><ylene0 p.P9xane 02OH 0.12 H26 .150
PreVlous FACILITY.TOTAL 0.0 6.1 6.1 6.3 0.3 6.6 6.1 1.6 at 00 0.0
01 1120000]0 01214-095391913 condensate 00n9e 6.2 129.1 n] 55.2 069.1
002 189.002 000(1)10v200,,,:,1 002(1) 0., ...0 m.. 62 003 GPO) 3esasemOsnmaem 009 606200 0 RICE 0 9 20240 0 15,952960 HP 350 _ 3030 00
(sne1ae61519-108010102a 0115
005 640200 51 RICE GM vorPc L 452689 HP. 0.6
papa 0t6N Bxv9819190360 •
006'6202 CN�' 523.65 00/425]5 aSRe BHP
•
(ste lalMk9N'-19'[1PoNA
00
OOY"GPo26iN sVNG22(0401e0011 1 BW HP:' a.0
(slrotgudl5TJP10E01M1051o09
06 GFD2 prelpaM02751409SRB BHP O.C
Tsn4re1ae16N'2]5tt935
600230 GM 412 4000410 00NP 0.0
(site Catea)SN;I0HMM500BON]
irsrte rare. 014204
011 OP03. SI '9526,09 HP
B192m
012 ORSON 592 9030356 a10?46 TA 283 HP
013 G1102 61 EF Cho p Ix G3906T0.27-6 HP.
019 GPM SI RICE...Mr G3a0011,
015 GP02 Valles 5 71 se 15210550
016 620230 a RICE0M'Ver.5.71,451715.190 0.0
011 GM CAT 03961A 216 Mr 04 32.0211
013 GP. 0
010 CROON erGMO0L 16Im.26106 - 0
XA External Car...Sources
xA Funds 12:9 17e 1_0 121 rlv 0.0
1OTALftpy)
•
9 11950910.013 11/30/2020
4.
s•,“,9A dti
Condensate Storage Tank(s) APENe,s'j-
ill410 444);-41
Form APCD-205
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 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: 17WE0970 AIRS ID Number: 123 / 1446/001
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Dunn 7 Sec HZ
Site Location
Site Location:
SWSW Sec 7 T5N R64W County: Weld .
NAICS or SIC Code: 1311
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203 Contact Person: Jack Starr
Phone Number: (303) 860-5800
E-Mail Address2: Jack.Starr@pdce.com
' 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.
9 P43-0
ICOLDRADo
o...a.a►�,1,,.m
FO'"l APL.,-2',.:.; ..O:IuC'1ShcC ?L%rdgp T8'lki`_ APE',_!: r:E',.. :.i 2 _., 1 I _ larm�w
Permit Number: 17WE0970 AIRS ID Number: 123 /1446/001
Section 2 - Requested Action
O NEW permit OR newly-reported emission source
❑ Request coverage under traditional construction permit
❑ Request coverage under a General Permit
O GP01 ,❑ GP08
If General Permit coverage is requested, the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-ON-
El MODIFICATION to existing permit(check each box below that applies)
O Change in equipment ❑ Change company name3
• Change permit limit ❑ Transfer of ownership's O 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&Notes: Requesting new throughput limit and emissions limits for Construction Permit 17WE0970;
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: 5/8/1986
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(EEP)site O Midstream or Downstream (non EEP)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Are Flash Emissions anticipated from these storage tanks? 0 Yes O No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? 0 Yes O No
If"yes", identify the stock tank gas-to-oil ratio: 0.003624 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) 0 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 0 Yes ❑ No
emissions≥6 ton/yr(per storage tank)?
�®/� COLORADO
t' ii'. ., L ..'�: - ;I�:""�' �' i���1l.,S� '.VF�r .� ".�. .._ i�i'G 2 ®iw
Permit Number: 17WE0970 AIRS ID Number: 123 /1446/001
Section 4- Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbl/year)
Condensate Throughput: 368,549 442,260
•
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 49.1 degrees RVP of sales oil: 7.8
Tank design: 0 Fixed roof 0 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 22 11,836 12/2016 6/2017
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 42828 Dunn 71-201 O
05 - 123 - 42833 Dunn 71-221 ❑
05 - 123 - 42823 Dunn 71-321 O
05 - 123 - 42830 Dunn 7L-201 O
05 - 123 - 42827 Dunn 7L-221 ❑
5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable,and should consider
future process growth. Requested values are required on all APENs,including APEN updates.
6 The 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)
40.40863/-104.59827
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)
❑Upward O Downward •
❑Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
O Circular Interior stack diameter(inches):
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
COLORADO
•
3 I
• .c o.wd.wawee.
s, °.ate.
Permit Number: 17WE0970 AIRS ID Number: 123 /1446/001
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 Size: Make/Model: •
El Recovery
Unit(VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Pollutants Controlled: VOC and HAPs
Rating: MMBtu/hr
hr
Type: Enclosed Combustors Make/Model: 14 x Cimarron 48",1 x Cimarron 60"
12U Requested Requested Control Efficiency: 95 %
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: Waste Gas Heat Content: 2,299 Btu/scf
Constant Pilot Light: ❑✓ Yes El No Pilot Burner Rating: MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
•
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested:
Section 7- Gas/Liquids Separation.Technology Information (EEtP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 34 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
COLORADO
Permit Number: 17WE0970 AIRS ID Number: 123 /1446/001
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 collection and control efficiencies(report the overall,or
combined,values if multiple emission control methods were identified in Section 6):
Collection Efficiency Control Efficiency
Pollutant Control Equipment Description (!K of total emissions captured (%reduction of captured
by control equipment) emissions)
i VOC Enclosed Combustor 100% 95%
NOx
j CO
HAPs Enclosed Combustor 100% 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 (AP-42, Emissions Emissions8 Emissions Emissions
Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
VOC 1.6122 Ib/bbl ProMax 297.08 1486 356.50 17.83
NO. 0.1380 Ib/MMBtu TCEQ N/A 1.70 N/A 2.02
CO 0.2755 Ib/MMBtu TCEQ N/A 3.59 N/A 4.23
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-criteria Yes ❑No
pollutants(e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year?
If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source:
Chemical Emission Factor? Actual Annual Emissions
Chemical Name Abstract Uncontrolled Source Uncontrolled Controlled
Service(CAS) Basis Units (AP-42, Emissions Emissions8
Number Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 0.0041 IbIbbi ProMax 1,503.38 75.17 —
Toluene 108883 0.0056 _ lb/bbl ProMax 2.051.61 102.58
Ethylbenzene 100414 2.11E-04 lb/bbl ProMax 77.69(DM) 3.88(DM)
Xylene 1330207 00025 Ib/bbl ProMax 919.51 45.98
n-Hexane 110543 0.0312 Ib/bbl ProMax 11.484.40 574.22
2,2,4-Trimethylpentane 540841 2.13E-04 Ib/bbl ProMax 78.48(DM) 3.92(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.
g COLOIrO
.. APC! L, nck:' v,t `to;ii'-l' IanVic1 r�PL4 • Yt.•_.,, i ..C', 5I we
X�IU i Pn-rm,wn
Permit Number: 17WE0970 AIRS ID Number: 123 /1446/001
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.
Sign re of Legally Authorized Person(not a vendor or consultant) Dat
Ja k Starr Senior Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
Q✓ Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made(significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with$191.13 and the General Permit For more information or assistance call:
registration fee of$312.50, if applicable, to:
Small Business Assistance Program
Colorado Department of Public Health and Environment (303)692-3175
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
�� \''�, .�_ L^;,E"ISd Cc i J'h.�_i i` :.� ^�.•.".SY. _ 6 I .® x�mrsm
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: PDC Energy,Inc.
Source Name: TK-1
Emissions Source AIRS ID2: 123/1446/001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-42825 Dunn 7L-301 ❑
05-123-42832 Dunn 7L-341 ❑
05- 123—42831 Dunn 7Q-221 0
05-123-42826 Dunn 7Q-241 ❑
05-123-42829 Dunn 7Q-301 ❑
05-123-42824 Dunn 7Q-341 ❑
- - ❑
0
0
0
0
- - ❑
- - ❑
- - ❑
- - ❑
- - ❑
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
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
Hello