HomeMy WebLinkAbout20191470.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
April 8, 2019
Dear Sir or Madam:
RECEIVED
APR 1 2 2019
WELD COUNTY
COMMISSIONERS
On April 11, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Wacker 10 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: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor I Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
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2019-1470
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Wacker 10 Sec HZ- Weld County
Notice Period Begins: April 11, 2019
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: Wacker 10 Sec HZ
Exploration it Production Well Pad
SWNW Quadrant of Section 10, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: The applicant is requesting a new permit in the non -
attainment area for twenty-two (22) 538 barrel fixed roof storage vessels used to store condensate
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section
III.C.1.a (25 tpy in a non -attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 18WE0951.CP1 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:
James Ricci
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
1 AV COLORADO
� n.`annrenmm�mmr.
01 Division
th & Environment
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
18WE0951
Facility Name:
Plant AIRS ID:
Physical Location:
County:
General Description:
Issuance: 1
PDC Energy, Inc.
Wacker 10 Sec HZ
123/5200
SWNW Quadrant of Section 10, Township 5N, Range 64W
Weld County
Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-1
001
(22) 538 barrel fixed roof storage
vessels used to store condensate
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. 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 shall
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 shall 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
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Page 1 of 9
this permit; (ii) discontinues construction for a
(iii) does not complete construction within a
pletion date. The Division may grant extensions
Part B, Section III.F.4.)
3. The operator shall complete all initial compliance testing and sampling as required in
this permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4. The operator shall retain the permit final authorization letter issued by the Division,
after completion of self -certification, with the most current construction permit. This
construction permit alone does not provide final authority for the operation of this
source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants shall not exceed the following limitations. (Regulation
Number 3, Part B, Section II.A.4.)
Annual Limits:
Facility
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
PM2.5
NO,
VOC
CO
TK-1
001
--
5.3
65.9
10.7
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods
used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant shall not exceed 8.0
tons per year.
Facility -wide emissions of total hazardous air pollutants shall not exceed 20.0 tons per
year.
The facility -wide emissions limitation for hazardous air pollutants shall apply to all
permitted emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, shall
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 shall calculate actual emissions each month and keep a compliance record on
site or at a local field office with site responsibility for Division review.
6. The emission points in the table below shall be operated and maintained with the
emissions control equipment as listed in order to reduce emissions to less than or equal
to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-1
001
Enclosed Combustors
VOC and HAP
COLORADO
Air Pollution Control Division
Department of Public Health Et Environment
Page 2 of 9
7. =This :u .e °fall •,� �ted «o `he fo owing maximum processing rates as listed below.
al proc ;.sing rates shall be maintained by the owner or
rat• ". d ' . • o a to th ision for inspection upon request. (Regulation
Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK-1
001
Condensate Throughput
690,450 barrels
The owner or operator shall monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits shall 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 shall 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) shall 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, Section XII. The operator shall comply
with all applicable requirements of Section XII and, specifically, shall:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for condensate 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, Section XII.C.) (State only
enforceable)
11. The combustion device covered by this permit is subject to Regulation Number 7,
Section XVII.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 XVII, it shall be enclosed; have no visible emissions during normal
operations, as defined under Regulation Number 7, XVII.A.16; 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 following schedule:
• All combustion devices installed on or after May 1, 2014, must be equipped with
an operational auto -igniter upon installation of the combustion device;
COLORADO
Air Pollution Control Division
Department of Pubf,c Health & Envirorvnent
Page 3 of 9
d before May 1, 2014, must be equipped with an
efore May 1, 2016, or after the next combustion
hever comes first.
12. - sto . - t. ve is p- is subject to the emission control requirements
in Regulation Number 7, Section XVII.C.1. The owner or operator shall 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 May 1, 2014. The source shall follow the inspection
requirements of Regulation Number 7, Section XVII.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, Section
XVII.C.2.
OPERATING a MAINTENANCE REQUIREMENTS
14. Upon startup of these points, the owner or operator shall follow the most recent
operating and maintenance (OEtM) plan and record keeping format approved by the
Division, in order to demonstrate compliance on an ongoing basis with the requirements
of this permit. Revisions to the OEtM plan are subject to Division approval prior to
implementation. (Regulation Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
15. The owner or operator shall 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, Sections XII.C, XVII.B.2. and
XVII.A.16)
Periodic Testing Requirements
16. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
17. A revised Air Pollutant Emission Notice (APEN) shall 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
COLORADO
Air Pollution Control Division
DecArtment of Public Heaith & Environment
Page 4 of 9
(VOC) and nitrogen oxides sources (NOx) in ozone
less than 100 tons of VOC or NOx per year, a
l emiss ns of one (1) ton per year or more or five percent,
bove � 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.
18. The requirements of Colorado Regulation No. 3, Part D shall apply at such time that any
stationary source or modification becomes a major stationary source or major
modification solely by virtue of a relaxation in any enforceable limitation that was
established after August 7, 1980, on the capacity of the source or modification to
otherwise emit a pollutant such as a restriction on hours of operation (Reference:
Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
19. 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.
20. 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.
21. 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
COPHE
COLORADO
Aix Pollution Control Division
Department of Pubtic tlath b Envirnnraent
Page 5 of 9
made by the owner or operator or owner or
for the equipment and operations or activity
22. ess if -:n st. -rwis-, e 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.
23. 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 shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall 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.
24. 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.
25. 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
James Ricci
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
New permit for condensate tanks at a
synthetic minor facility
COLORADO
Mr Pollution Control Division
Department of Pnbl', Health £Erwironment
Page 6 of 9
Notes 1;• Pe it wEtT.lra-r at tim-. his p mit issuance:
1) Th per t l• N is r qui ;-d tf p.` fee • ` or the processing time for this permit. An invoice
foer the rmit is issued. The permit holder shall pay the
i wi 3 ' `• :r" o •' of t voice. 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 shall
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
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
(lb/yr)
001
Benzene
71432
4716
236
Toluene
108883
5654
283
Ethylbenzene
100414
229
11
Xylenes
1330207
2170
108
n -Hexane
110543
48234
2412
2,2,4-
Trimethylpentane
540841
261
13
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.
COLORADO
Air Pollution Control Division
Department of Pubk Health & Enyfrorvoent
Page 7 of 9
it are based on the following emission factors:
CAS #
Pollutant
U rolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
1.55 x 10-2
TCEQ
CO
3.09 x 10-2
TCEQ
VOC
3.82 x 10°
1.91 x 10-1
ProMax
71432
Benzene
6.83 x 10-3
3.41 x 10-4
ProMax
108883
Toluene
8.19 x 10-3
4.09 x 10-4
ProMax
100414
Ethylbenzene
3.31 x 10-4
1.66 x 10-5
ProMax
1330207
Xylene
3.14 x 10-3
1.57 x 10-4
ProMax
110543
n -Hexane
6.99 x 10-2
3.49 x 10-3
ProMax
540841
Trimethylpentane
3.79 x 10-4
1.89 x 10-5
ProMax
Note: The controlled emissions factors for this point are based on the enclosed combustor
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 shall be submitted no later than 30 days before the five-
year term expires. Please refer to the most recent annual fee invoice to determine the
APEN expiration date for each emissions point associated with this permit. For any
questions regarding a specific expiration date call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule
805b(2)(A) when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, n -Hexane, Total HAPS
NANSR
Synthetic Minor Source of: VOC
MACT HH
Major Source Requirements: Not Applicable
Area 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://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart KKKK
COLORADO
Air Pollution Control Division
Department of Public Health ff Environment
Page 8 of 9
SPS60'
p -ndix r,
ppe i ix A - Appendix
art Ny :
or'.
' • ti al'mis.• n `° andard or Hazardous Air Pollutants for Source
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
COLORADO
Air Pollution Control Division
Department of Public Health 6 environment
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: lames Ricci
Package #: 386445
Received Date: 8/30/2018
Review Start Date: 1/18/2015
Section 01- Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: ;5200
Facility Name: Wacker 10 Sec HZ
Location: SWNW Quadrant of Section 10, Township 5N, Range 64W
County: Weld County
Type of Facility: `Exploration & Production Well Pad
What industry segment?Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? ..es
If yes, for what pollutant? ❑ Carbon Monoxide (co) ❑
Section 02 - Emissions Units In Permit Application
Quadrant
Section
Township
Range
SWNW
10
5N
64
Particulate Matter (PM) O Ozone (NOx & Cot)
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance it
SelfCert .
Required?
Action
Engineering
Remarks
001
Conceusatelark
TK-7.
Yes -
18WE0951.CP1
1
Yes -
Permit initial
Isskance
Section 03 - Description of Project
Liquids from twelve (11) wells flow through heated separators where the fluid is separated into gas, water and hydrocarbon (condensate). The condensate flows to (22)538 bb( condensate !.
tanks These twenty-two (22) tanks are the source of emissions that PDC is: requesting to permit.
Section 04- Public Comment Requirements
Is Public Comment Required?
If yes, why?
hetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO voc PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ 0
Title V Operating Permits (OP) 0 ❑ 0 0 ❑ ❑ ❑ 0
Non -Attainment New Source Review (NANSR) ❑ 0
No
Is this stationary source a major source?
If yes, explain what programs and which pollutants her SO2
Prevention of Significant Deterioration (PSD) ❑
Title V Operating Permits (OP) ❑
Non -Attainment New Source Review (NANSR)
NOx
CI
CO
0
VOC
PM2.5 PM10 TSP HAPs
❑ ❑ ❑
❑ ❑ ❑ ❑ ❑
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
(Facility A1Rs ID:
123
County
PPP ° 001
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device lo
Description:
Requested Overall VOC & HAP Control
Efficiency%:
ed roof storage vessels used t store condensate..
Eleven (11)48" Cimarron and One (1) 60° Cimarron,
Section 03- Processing Rate {Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput=
590;450 ` " Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
Requested Monthly Throughput=
690,450 Barrels (bbl) per year
Barrels (bbl) per year
58641 Barrels (bbl) per month I
Potential to Emit (PTE) Condensate
Throughput=
Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas= 2000' Btu/scf
Volume of waste gas emitted per BBL of
liquids produced = „ scf/bbl
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
(applicant assumed)
77,344 MMBTU per year
77,344 MMBTU per year
92,813 MMBTU per year
Pollutant
Pollutant
Uncontrolled
Controlled
(lb/bbl)
(Ib/bbl)
(Condensate
Throughput)
..1,..0.0068.. F..,
'0.0003`"
0.0699
' 0.0004
(Condensate
Throughput)
0,000
0.000
0.000
0.000
0,003
0.000
Control Device
Uncontrolled Uncontrolled
(lb/MMBtu)
waste heat
combusted)
(lb/bbl)
Section 05 - Emissions Inventory
(Condensate
Throughput)
0.0000
0.0000
0.0309
Emission Factor Source
Emission Factor Source
From ProMax (lb/h)
Flash
W&B
249.8228
50.89951254
0.476177
0.0621472
0.56656
0.0788357
0.0226652
0.00344561
0,206332
0,0413377
4.59706
0.909062
0.0250406
0.00479533
Potential to Emit
Actual Emissions
Requested Permit Limits
Requested Monthly Limits
Criteria Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
Controlled
(tons/year)
(tons/year) (tons/year)
(tons/year) (tons/year)
(lbs/month)
VOC
1580.6
1317.2
65.9
1317.2
65.9
11187
PM10
0,0
0.0
0.0
0.0
0.0
0
PM2.5
0,0
0,0
0.0
0.0
0.0
0
NOx
6.4
5,3
5.3
5.3
5.3
907
CO
12.8
10.7
10,7
11
10.7
1810
Potential to Emit
Actual Emissions
Requested Permit Limits
-
HazardousAirPollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(lbs/year) (lbs/year)
(lbs/year) (lbs/year)
Benzene
5659
4716
236
4716
236
Toluene
6784
5654
283
5654
283
Ethylbenzene
274
229
11
229
11
Xylene
2604
2170
108
2170 '
108
n -Hexane
57880
48234
2412
48234
2412
224 TMP
314
261
13
261
13
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
Source requires a permit
Regulation 7, Section XII.C, D, E, F
Storage tank is subject to Regulation 7, Section XII,C-P
Regulation 7, Section XII.G, C
Storage Tank is not subject to Regulation 7, Section XII.G
Regulation 7, Section XVII.B, C.1, C.3
Storage tank is subject to Regulation 7, Section XVII, B, C,1 & C.3
Regulation 7, Section XVII.C.2
Storage tank is subject to Regulation 7, Section XVII,C.2
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not subject to NIPS Kb
Regulation 6, Part A, NIPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation S, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HI -I
(See regulatory applicability worksheet for detailed analysis)
2 of 4
K:\PA\2018\18W E0951.CP1.xlsm
Condensate Storage Tank(s) Emissions Inventory
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use thestate default emissions factors to estimate emissions?
If yes, are the uncontrolledactual or requested emissions estimated to be greater than or equal to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01
Does the company use a site specific emissions factor to estimate emissions?
if yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? Thissample 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 may be appropriate to use an older site -specific sample.
If no, the permit will contain en "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01
Does the company request a control device efficiency greater than 95% for a flare or combustion device?
If yes, the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampliry
Section 08 -Technical Analysis Notes
Primary Emissions
The apnlfcunt used simulations in Pro Max to derv_ site specific emission factors. Flash emission were combined with Working and Breathing losses to determine total emissions per bbl of
condensate. For this simulation, a sample of pressurized liquid was taken from the Wacker 10 well on 8/17/18 (119 deg F and 27.2psig) and analyzed by Alliance testing on 8/17/2018.
Secondary Emissions - Combustion Device
The applicant calculated Flash Gas (MMBtu/yr) as follows:
•
MMBtu tan ( lSCF Gar 1 MMBtu
Flash Gas UncoUncontrolledVOf. x 2000 b x x 379.41 x x Heat Content }x 1
�Btu
yr (21')
Gas h J ! l �VOC %� SCF/ (10s,1O
This equation was used in conjunction with flash gas properties from a ProNlax simulation that was ran with a representative composite flash gas analysis as an input. The gas molecul
is 3816/Ib-mol, the VOC percentage used is 68%, and the heat content used is 2,000 btu/scf. This equated to Flash Gas being 77,344.43 Mono"
Alternatively, you can calculate Flash Gas using the average weighted heat content of waste gas and volume of
•'. values, I calculated 74,758 of waste gas. Since the applicant's value is more conservative, itwas accepted.
Section 09'- Inventory SCC Coding and Emissions Factors
AIRS Point#
001
Process# SCC Cade
01 >.. .
este gas emitted per bbl of liquids produce, also taken from ProMa:
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.37 0 16/1,000 gallons condensate throughput
VOC 90.8 95 lb/1,000 gallons condensate throughput
CO 0.73 0 lb/1,000 gallons condensate throughput
Benzene 0.16 95 lb/1,000 gallons condensate throughput
Toluene 0.19 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.01 95 lb/1,000 gallons condensate throughput
Xylene 0.07 95 lb/1,000 gallons condensate throughput
n -Hexane 1.66 95 lb/1,000 gallons condensate throughput
224 TMP 0.01 95 lb/1,000 gallons condensate throughput
3 of 4 K:\PA\2018\18W E0951.CP1.xlsm
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B -ADEN and Permit Requirements
'Source Is in the Non.Attainmenturea
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this Individual source greater than 2 TPY (Regulation 3, Part A, Section 11.0.1.a)?
2. Isthe constmction date (service date) pdorto 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)?
3. Are totalfacllgy uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10IVY (Regulation 3, Part B, Section 11.0.3)?
Yon have indicated that source Is in the Non -Attainment Area
NON.ATTAINMENP
1. Are uncontrolled emissions from any criteria pollutants from thy individual source greaterthan 1TPY (Regulation 3, Part A, Section 11.0.1.a)?
2. Is the construction date (service date) pdorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Definitions 112 and1.14 and Section 2 for addrtional guidance on grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 2TPY, NOx greater than 5TPY or CO emissions greater than to 'MY (Regulation 3, Part B, Section 11.0.2)?
'Source requires a permit
Colored° Regulation 7, Section XII.C-F
1. Is this storagetenk located In the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance areal
2. Is this storagetank located at an oil and gas exploration and production operation, natural gas comprssorstation or natural gas drip station?
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
S000icoXll.C.2 — Emission Estimation Procedures
Section %II.D— Emissions Control Requirements
Section XII.E— Monitoring
Section 3110—Recordkeeping and Reporting
Colorado Regulation 7. Section X116
1. Is this storage tank located in they -hr ozone control area orany ozone non -attainment area or attainment/maintenance areal
2. Is this storage tank located at a natural gas processing plant?
3. Does this storagetank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greaterthan or equal to 2 tonsperyearVOC?
Yes
Yes
mew
Yes
No
'Storage Tank is not subject to Regulation 7, Section XII.G
Section %11.0.2- Emissions Control Requirements
Section XII.GI —General Requirements for Air Polluter Control Equipment —Prevention of Leakagr
Section etl.ca—Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensatestorage tank' located at an oil and gas exploration and production operation, well production facility?, natural gas compressor stations or natural gas procesing plant?
3. 'stills Condensatestorage tank a fixed roof storage tank?
4. Are uncontrolled actual emissions" of this. storage tank equal to or greater than 6 tons per year VOC?
'Storagetank is subject to Regulation 7, Section XVII, B, Gt H C.3
Section XVI1.B— General Provisions forAir Pollution Control Equipment and Prevention of Emission
Section IMI.C.1-Emissions Control and Monitoring Provisions
Section IMI.C.3 - lecordkeeping Requirements
5. Does the condensate steragetank contain only "stabilized" liquids?
'Storage tank is subject to Regulation 2, Section 1MI.C.2
Section MI..- Capture and Monitoring for Storage Tanks fated with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance far Volatile Organic Liquid Storage Vessels
1. Is the Individual storage vessel capacity greater thanor equal to 75 cubic meters (ma) ["472 BBLd?
2. Does the storagevessel meet the following exemption In 60.111b(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589874 ma (-10,000 BBL] used for petroleum' or condensate stored, processed, ortreated priorto custody transfef as defined In 60.1116?
3, Was this condensate storage tank constructed,reconstructed, or modnted(see definitions 40 CFR, 60.2) afterJuly 23, 1984? a
4. Does the tank meet the definition of "storage vessert In 60.1116?
5. Does the storagevessei store a"volatile organic liquid (VOL)"aas defined In 60.111b?
6. Dos the storage vessel meet any one of the following additional exemptions;
a. Is the storage vessel a pressure vessel designed to operate in excess of 204.9 kPa [^29., psi] and without emissions to the atmosphere (60.11ob(d)(2))?; or
b. The design capacity is greater than or equal to 151 rrra [•950 BBL] and stores a liquid with a maximum true vapor pressures less than 3.5 kPa (60.110b(b)(?; or
c The design rapacity Is greater than or equal to 75 Ms (-472 BBL] but less than 151 ma [-950 BBL] and stores a liquid with a maximum true vapor pressures less than 15.0 kPa(60.110b(b()?
I
Storage Tank is not subject to NSPS Kb
Subpart A, General Provisions
460.112b- Emissions Control Standards for VOC
§6o.113b-Testing and Procedures
§60.115b-Repordngand Recordkeeping Requirements
§60.110k -Monitoring of Operations
40 CFR, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1. Is this condensate 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?
2. Was this condensate storage vessel constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) between August23, 2011 and September 18, 2035?
3. Are potential VOC emissions' from the individual storage vessel greaterthan or equal to 6 tons per year?
4. Dam this condensate storage vessel meet the definition of"storage vessel"' per 605430?
5. 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 63subpart HH?
'Storage Tank is not subject to NSPS 0000
Subpart A, General Provisions per 3605425 Table 3
§60.5395 - Emissions Control Standards for VOC
460.5413 - Testing andProcedurs
§00.5395(g) - Notification, Reporting and Remrdkeeping Requirement
§605416(c) - Cover and Closed Vent System Monitoring Requirements
060.5417 - Control Device Monitoring Requirements
looter if a storage vessel is prevlously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC an the applicability determination date, it should remain subject to NSP60000 per 60.5365(e)(2) even If
potential VOC emissions drop below 6tons per year]
40 CFR. Part 63. Subpart MAKT NN, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facilitythetprocesses, upgrades or stores hydrocarbon liquids' (63.760(4(2)); OR
b. A facilitythatpmcesses, upgrades or stores natural gas pdorto the point at which natural gas enters the natural gas transmission and storagesource category or is delivered to a final end usei(63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tankmeet the definition of "storage vessel'4 in 63.761?
4. Dosthetank meet the definition of°storage vessel urn the potential forflash eminionsi° per63.761?
5. Is thetank subject to control requirements under 40 CFR Part 60, Subpart Kb orsubpart 0000?
'Storage Tank Is not subject° MACT NH
SubpartA, General provislcns per 463.764 (a) Table 2
063.766 - Emissions Control Standards
§63.773 -Monitoring
§63.774-Reccrdkeeping
463.775 -Reporting
RACT Review
RAC'review Is required if Regulation 7 does not apply AND If the tank Is In the non -attainment ores. If the tank meets both crlteda, then review RACT requbements.
Diselalntel
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
e rule or regulation, and the anahois it contains may not apply to a particular situation based upon the individual facts and circumstances. This document does not change orsubstiMe for any law, regulation,
or other legally binding requirement and is not legally enbmeeble. In the event of any conf between the language of this document and the language of the Clean Air Act„ its implementing regulations,
and Air QualdyConbol Commission regulations, the language oft he statute or regulation will control. The use of non -mandatory language such as'recommend,°"may,"should,"and "can,' is intended to
describe APCO interpretations and recommendations. Mandatory Terminology such as 'must* and "requirecr are intended to describe controlling requirements undertha terms of the Clean Air Act and Air
Quality Control Commission regulations but this document does not establish legally binding requirements in and of itself.
No
Yes
rdititoe
4.a °�iA
Y"i.
NA n.,'x` `,
Yes
NA e
'bas 1
Condensate Storage Tank(s) APEN -
Form APCD-205
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. 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 loadings, 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.gov/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.
AIRS ID Number: 123 /5200 / 001
RECEIVED1, ;
AU6302018
Permit Number:
(5wEO95J _
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name:
Site Name:
Site Location:
PDC Energy, Inc.
Wacker 10 Sec HZ; Waer
SWNW Sec 10 T5N R64W
A
Mailing Address: 1775 Sherman Street, Suite 3000
(Include Zip Code)
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Permit Contact: Jack Starr
Phone Number: (303) 860-5800
E -Mail Address2: Jack.Starr@pdce.com
i 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 APCD via e-mail to the address provided.
Form APCD-205 Condensate Storage T ank(s) APEN - Revision 02/2017
COLORADO
1 hivth-, i.ent a F.,e
Permit Number: AIRS ID Number: I L3 /OLuu / uu I
[Leave blank unless APCD has already assigned a permit if and AIRS ID]
Section 2 - Requested Action
✓❑ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
O Request coverage under a General Permit
O GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $250 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name
❑ Change permit limit O Transfer of ownership3
OR -
▪ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
APEN submittal for permit exempt/grandfathered source
O Other (describe below)
Additional Info a Notes: Eleven (11) new well additions to a previously permitted facility; Requesting
Construction Permit coverage in place of currently existing GP -01 coverage; Additional equipment added to location
3 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
For existing sources, operation began on:
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
10/15/1985
hours/day 7 days/week
❑✓ Exploration Et Production (EEtP) site
52
weeks/year
O Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
p
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
S
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
0
Yes
•
No
If "yes", identify the stock tank gas -to -oil ratio:
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)el
805 series rules? If so, submit Form APCD-105.
Yes
No
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
O
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
®r COLORADO
2 I : of PuLUc
Hw1 n b Enr.nnmen
Hermit Numoer:
AIKJ W Numoer: I L.3 /oLuu / uu I
[Leave blank unless APCD has already assigned a permit ft and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limit4
(bbl /year)
Condensate Throughput:
690,450
From what year is the actual annual amount?
2018
Average API gravity of sales oil: 49.3 degrees
O Internal floating roof
Tank design: ❑✓ Fixed roof
690,450
RVP of sales oil: 8.1
❑ External floating roof
Storage
Tank ID
# of Liquid Manifold Storage
Vessels in Storage Tank
Total Volume of
Storage Tank
(bbl)
Installation Date of Most
Recent Storage Vessel in
Storage Tank (month/year)
Date of First
Production
(month/year)
TK-1
11.. i
' 1 l g; 6 1
6/2017
10/1985 a
Wells Serviced by this Storage Tank or Tank Battery5 (MP Sites On y)
API Number
Name of Well
Newly Reported Well
05
- 123-
43567
Wacker 10E-204
0
05
- 123-
43561
Wacker 10E-232
I9
05
- 123-
43565
Wacker 10E-234
Fl
05
- 123-
43564
Wacker 10E-302
0
05
- 123-
43563
Wacker 10E-304
0
4 Requested values will become permit Limitations. Requested limit(s) should consider future growth.
5 The EFtP 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)
40.415468 / -104.544237
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
Indicate the direction of the stack outlet: (check one)
o Upward
D Horizontal
❑ Downward
0 Other (describe):
Indicate the stack opening and size: (check one)
❑ Circular
❑ Square/rectangle
❑ Other (describe):
0 Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017
3j_ COLORADO
L3:�4 H. art uvm< nmen,
Permit Number:
AIKb IU Number: ILJ nJLuu I till I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
Vapor
❑ Recovery
Unit (VRU):
Pollutants Controlled:
Size:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
%
❑ Combustion
Device:
Pollutants Controlled: VOC & HAPs
Rating:
Type: Enclosed Combustor
Requested Control Efficiency:
MMBtu/hr
hr
Make/Model: 11 x Cimarron 48", 1 x Cimarron 60"
95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
%
Waste Gas Heat Content:
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating:
O Closed Loop System
O Other:
Description of the closed loop system:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Btu/scf
MMBtu/hr
%
Section 7 -Gas/Liquids Separation Technology Information (EftP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 27.2 psig
Describe the separation process between the well and the storage tanks: High/Low Pressure Separator
Form APCD-205 - Condensate Storage Tank(s) APED - Revision 02/2017
A�y
COLORADO
4I .o�m. x
rermit numoer:
HIRJ IL! rlunn) I : I L,J
I vwv I WSJ I
[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 form6.
If multiple emission control methods were identified in Section 6, the following table can be used to state the overall
(
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustor
95%
NOx
CO
HAPs
Enclosed Combustor
' 95%
Other:
From what year is the following reported actual annual emissions data?
2018
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor6
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)4
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions 7
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
3.81461
lb/bbl
ProMax
1,316.90
65.85
1,316.90 i
65.85 ✓
NOx
0.1380
Ib/MMBtu
TCEQ
N/A
5.34
N/A ✓
5.34 ✓
CO
0.2755
Ib/MMBtu
TCEQ
N/A
10.65
N/A ✓
10.65 r
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical
Emission Factor6
Actual Annual Emissions
Chemical Name
Abstract
Service CAS
( )
Number
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg: etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions7
(Pounds/year)
Benzene
71432
0.0068
lb/bbl
ProMax
4,715.71 ✓
235.79 ✓
Toluene
108883
0.0082
lb/bbl
ProMax
5,653.70 1
282.69
Ethylbenzene
100414
0.0003
lb/bbl
ProMax
228.73 (DM) ✓
11.44 (DM) '°
Xylene
1330207
0.0031
lb/bbl
ProMax
2,169.62 ✓
108.48 ✓
n -Hexane
110543
0.0699
lb/bbl
ProMax
48,233.40 ✓
2,411.67 ✓
Trimethylpentane
540841
0.0004
lb/bbl
ProMax
261.37 .
13.07''
4 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 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.
7 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 02/2017 5
AV
COLORADO
11,u -anon: of rust.
Hau!,t; b Envrn.un��i
Permit Number:
AIRS ID Number: 123 It ZUU / UU1
[Leave blank unless APCD has already assigned a permit d 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.
772-i / 7
Sign re of Legally Authorized Person (not a vendor or consultant) Da e
Jack Starr Air Quality Representative
Name (print)
Title
Check the appropriate box to request a copy of the:
❑ Draft permit prior to issuance
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 $152.90 and the General Permit
registration fee of $250, if applicable, to:
Colorado Department of Public Health and
Environment
Air Pollution Control Division
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
Telephone: (303) 692-3150
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 02/2017
;COLORADO
6 1 A
Heatih 6 Envi�onmeni
Company Name:
PDC Energy, Inc.
Source Name:
Wacker 10 Sec HZ; Wacker 1
Emissions Source AIRS ID2:
123 / 5200 / 001
stt
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number ,
Name of Well
Newly Reported Well
05-123-43559
Wacker 10G-212
Al
05 - 123 - 43568
Wacker 10G-214
Al
05 -123 - 43560
Wacker 10G-302
05 - 123 - 43562
Wacker 10G-304
1
05 -123 - 43566
Wacker 10G-312
A
05 -123 -/,3569
Wacker 10G-314
05 - 2 12591
Wac1
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
- -
- -
❑
Footnotes:
1 Attach this addendum to associated APEN form when needed to report additional wells.
2 If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
TK-1 Addendum
[Quoted text hidden]
Ricci - CDPHE, James <james.ricci@state.co.us> Mon, Apr 1, 2019 at 7:16 AM
To: Jack Starr <Jack.Starr@pdce.com>
Yea, no problem.
Thanks,
James Ricci
Permit Engineer
CDPH
'COLORADO
Air Pollution Control Division
Department of Public Health & Emnronment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
[Quoted text hidden]
Jack Starr <Jack.Starr@pdce.com>
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
Mon, Apr 1, 2019 at 12:21 PM
Hi James,
Thank you for the extension to review draft permit 18WE0951! I was able to take a look at it this morning and have PDC's comments below:
Facility Name (Page 1) — Please change the name from "Wacker 10 Sec 10HZ; Wacker 1" to just "Wacker 10 Sec HZ; Wacker 1".
Permit Condition 1: Submittal of a Notice of Startup (NOS) — Because AIRS ID 123/5200/001 is an existing point that was previously
operating under a Condensate Storage Tank General Permit (GP -01), can this condition be removed? If the point previously existing is not
enough of a reason to remove the condition, may I submit an electronic Notice of Startup (e -NOS) and send you a copy of the receipt as
proof in order to get the condition removed?
Additionally, the Wacker 1 well was plugged and abandoned back in December of 2018 and the 300 barrel storage tank associated with it
has since been removed. Would it be possible to reflect this in the permit? Or will an APEN update need to be submitted? No changes to
the annual process rate or emissions will be necessary. I believe the only changes this would lead to are the Facility Name being shortened
to "Wacker 10 Sec HZ" and the Equipment Description being shortened to "Twenty-two (22) 538 barrel fixed roof storage vessels used to
store condensate".
Please let me know your thoughts on these comments at your earliest convenience.
Thanks again,
Jack Starr
Air Quality Representative - Wattenberg
(303) 318-61611 Direct
(720) 501-86111 Cell
https://mai I.google.com/mail/u/0?[k=5517734b80&view=pt&search=all&permthid=thread-f%3A1623317809880081626&simpl=msg-f%3A16233178098... 4/7
ENERGY
PDC Energy 11775 Sherman Street Ste 3000 I Denver, CO 80203 I NASDAQ: PDCE
This email, including attachments, may include confidential and/or proprietary information, and may be used only by the person or entity to which it is addressed. Please do not read, copy or
disseminate this communication unless you are the intended addressee. If you received this communication in error, please permanently delete and call (800) 624-3821 immediately and ask to
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Please consider the environment before printing this e-mail. Thank You.
From: Ricci - CDPHE, James[mailto:james.ricci@state.co.us]
Sent: Monday, April 1, 2019 7:16 AM
To: Jack Starr <Jack.Starr@pdce.com>
Subject: Re: [EXTERNAL] :Wacker 10 Sec 10HZ; Wacker 1- Condensate Tanks - AIRS ID 123/5200
Yea, no problem.
Thanks,
James Ricci
Permit Engineer
[Quoted text hidden]
[Quoted text hidden]
Ricci - CDPHE, James <james.ricci@state.co.us> Mon, Apr 1, 2019 at 2:44 PM
To: Jack Starr <Jack.Starr@pdce.com>
Jack,
With your permission, I will make the following APEN Redlines:
Change the facility name to "Wacker 10 Sec HZ "on all the APENs (Condensate Tanks, GP02s, GP07)
Section 4 of the Condensate Tank APEN:
o Redline # of vessels to 22 v-
O Redline Total Volume to 11,836 bbl
o Remove the Wacker 1 Well from the Addendum
o Am I missing any other changes needed on the APEN based on the PICA of that well?
I will also update the Condensate Permit with this new facility name and tank description.
Regarding the NOS, we will still require it. If you can send me a receipt, I will remove this condition from the draft permit.
Thanks,
James Ricci
Permit Engineer
https://mai I.google.com/mai I/u/0?i k=5517734b80&view=pt&search=all&permthid=thread-f%3A1623317809880081626&simpl=msg-f%3A16233178098... 5/7
Department of Public Health & En,ronment
P 303.691.4089 I F 303.782.0278
4300 Cherry Creek Drive South, Denver, CO 80246
james.ricci@state.co.us I www.colorado.gov/cdphe/apcd
[Quoted text hidden]
Jack Starr <Jack.Starr@pdce.com> Wed, Apr 3, 2019 at 5:56 PM
To: "Ricci - CDPHE, James" <james.ricci@state.co.us>
James,
Please proceed with the APEN redlines you listed below. I believe those are all of the changes that are needed based on the Wacker 1 well
having been P&A'd. If it's not too much trouble, can you send me copies of the redlined APENs for PDC's records?
Also, please see attached the eNOS receipt for the Wacker 10 Sec HZ condensate tanks.
If there's anything else you need from me, please do not hesitate to let me know.
Thanks,
Jack Starr
Air Quality Representative - Wattenberg
(303) 318-61611 Direct
(720) 501-86111 Cell
Jack.Starr@pdce.com
C% PDC
WY ENERGY
PDC Energy 11775 Sherman Street Ste 3000 j Denver, CO 80203 I NASDAQ: PDCE
This email, including attachments, may include confidential and/or proprietary information, and may be used only by the person or entity to which it is addressed. Please do not read, copy or
disseminate this communication unless you are the intended addressee. If you received this communication in error, please permanently delete and call (800) 624-3821 immediately and ask to
speak to the sender of this communication. Also, please notify immediately via e-mail that you have received this message in error.
APlease consider the environment before printing this e-mail. Thank You.
From: Ricci - CDPHE, James [mailto:james.ricci@state.co.us]
Sent: Monday, April 1, 2019 2:45 PM
To: Jack Starr <Jack.Starr@pdce.com>
Subject: Re: [EXTERNAL] :Wacker 10 Sec 10HZ; Wacker 1- Condensate Tanks - AIRS ID 123/5200
https://mai I.goog le.com/mail/u/0?i k=5517734b80&view=pt&search=all&permthid=thread-f%3A1623317809880081626&simpl=msg-f%3A16233178098... 6/7
Hello