HomeMy WebLinkAbout20193075.tiff�u o
COLORADO
Department of Public
Health & Environment
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
July 2, 2019
Dear Sir or Madam:
RECEIVED
JUL 082019
WELD COUNTY
COMMISSIONERS
On July 4, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Fern 11 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.
Regards,
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
r' tai
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
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
P 1(J1ic Vie(.,c)
071 9(4/11 o7/i 7O9
cc • PLCTP), 8H(ST),
pcw(eR/Chl /urn/c K)
2019-3075
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Fern 11 Sec HZ - Weld County
Notice Period Begins: July 4, 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: Fern 11 Sec HZ
EEtP Well Pad
NWNW Sec 11 T5N R65W
Weld County
The proposed project or activity is as follows: New EEtP well production facility located in the Ozone non -
attainment area. Permitted equipment will include a condensate storage tank battery (19WE0409),
hydrocarbon loading rack (GP07), and several engines for compression and electrical power generation
(GP02). Tanks service ten (10) newly drilled wells as a new facility.
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 19WE0409 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:
Ben Fischbach
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
11*
COLORADO
Department of Public
Health 6 Environment
Denver, Colorado 80246-1530
COLORADO
21
Department of Public
Health b Environment
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Ben Fischbach
Package #: 389679
Received Date: 4/5/2019
Review Start Date: 6/5/2019
Section 01- Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
NWNW
11
5N
65
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
A041
Fern 11 Sec HZ
NWNW quadrant of Section 11, Township 5N, Range 65W
Weld County
Type of Facility: Exploration & Production Well Pad
What industry segment?Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? ❑ Carbon Monoxide (CO) ❑ Particulate Matter (PM) El
Section 02 - Emissions Units In Permit Application
Ozone :NOx & VOC)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Perm t #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001
Condensate Tank
Yes
19WE0409
I
Yes
Permit initial
Issuance
Section 03 - Description of Project
Initial permit application for twenty (20) 538 -bbl condensate tanks at a new E&P Facility. This tank battery utilizes two forms of control; the battery is preceded by a VRU
which captures and compresses condensate tank vapors into a pipeline for sales during VRU uptime, and routes the vapors to an ECD bank during VRU downtime.
In addition to point 001, PDC is permitting a loadout point (002) on a GP07, and six (003-008) RICEs on 3P02s.
Section 04 - Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05 - Ambient Air Impact Analysis Requiremen
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes, indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP 1-APs
Prevention of Significant Deterioration (PSD) ❑ ❑ ❑ ❑ ❑ ❑
Title V Operating Permits (OP) ❑ 2 Q El ❑ ❑ 0 ❑
Non -Attainment New Source Review (NANSR) 0 0
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 CO VOC PM2.5 PM10 TSP 1-APs
❑ D D D ❑
O ❑ ❑ ❑ ❑ ❑ ❑
❑ D
Condensate Storage Tank(s) Emissions Inventory
Section 01- Administrative Information
Facility AIRs ID:
123
County
A041
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Twenty (20) 533 bbl Condensate Tanks
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Tanks are connected to a VRU with 38% uptime, 62% downtime. During VRU downtime, emissions routed so standard
RD with 95% destruction efficiency.
96.9 %
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Total (process 01 + process 02)
Actual Condensate Throughput = 1,222,084 Barrels (bbl) per year
Requested Permit Limit Throughput = 1,466,500
Actual Condensate Throughput Whi e Emissions Controls Operating =
1,222,084 Barrels (bbl) per year
Barrels (bbl) per year
Requested Monthly Throughput =
124552 Barrels (bbl) per month
Potential to Emit (PTE)
Condensate Throughput = 1,466,501 Barrels (bbl) per year
Process 01 (emissions routed to VRU)
Actual Condensate Throughput = 464,392
Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
464,392 Barrels (bbl) per year
Requested Permit Limit Throughput = 557,270 Barrels (bbl) per year
Requested Monthly Throughput =
4733 Barrels (bbl) per month
Potential to Emit (PTE)
Condensate Throughput = 557,270 Barrels (bbl) per year
Requested Overall VOC & HAP Control
Efficiency %: 100
o'
Process 02 (emissions routed to Enclosed Flare)
Actual Condensate Throughput = 757,692
Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
757,692 Barrels (bbl) per year
Requested Permit Limit Throughput =
909,230 Barrels (bbl) per year
Requested Monthly Throughput =
77222 Barrels (bbl) per month
Potential to Emit (PTE) Condensate
Requested Overall VOC & HAP Control
Efficiency %:
909,230 Barrels (bbl) per year
95 %
Secondary Emissions from Process 02 - Combustion Device(s)
Heat content of waste gas
Volume of waste gas
emitted per BBL of liquids
produced =
2320 Btu/scf
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?
Yes
63,477 MMBTU per year
76,173 MMBTU per year
76,173 MMBTU per year
Process 01 (to VRU)
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Condensate
Throughput)
(Condensate
Throughput)
VOC
1.36
0.00
Site Specific E.F. (includes flash)
Benzene
0.003
0.00
Site Specific E.F. (includes flash)
Toluene
0.005
0.00
Site Specific E.F. (includes flash)
Ethylbenzene
0.000
0.00
Site Specific E.F. (includes flash)
Xylene
0.002
0.00
Site Specific E.F. (includes flash)
n -Hexane
0.029
0.00
Site Specific E.F. (includes flash)
224 TMP
0.000
0.00
Si 4, .,,F,_, a, ciat≥:.t4
..w.�.
i
..r.—
.
p
7 s F i Y /S 6 t /rt f:44) �/ t:(
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✓/... .!
i /i /,a. _is<Y
_
f
- -
».--....-ww•..,...-.-.-:....�.
_
..
w-••-
-.- ._
,.e,.
...
Process 02 (to Enclosed Flare)
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(Ib/bbl) (Ib/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
1.363
0.068140
Site Specific £.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Benzene
0.0034
0.000169
Toluene
0.0051
0.000255
Ethylbenzene
0.0002
0.000008
Xylene
0.0021
0.000103
n -Hexane
0.0290
0.001451
224 TMP
0.0001
0.000006
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MMBtu) (Ib/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM 10
0.0000
TNRCC Flare Emissions Guidance (NOx)
TNRCC Flare Emissions Guidance (CO)
PM2.5
0.0000
NOx
0.1380
0.0116
CO
0.2755
0.0231
K:\PA\2019\19WE0409.CP1
Condensate Storage Tank(s) Emissions Inventory
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx
CO
999.3
832.7
25.8
999.3
31.0
5262
0.0
0.0
0.0
0.0
0.0
0
0.0
0.0
0.0
0.0
0.0
0
5.3
4.4
4.4
5.3
5.3
893
10.5
8.7
8.7
10.5
10.5
1782
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(lbs/year)
Actual Emissions
Uncontrolled Controlled
(lbs/year) (lbs/year)
Requested Permit Limits
Uncontrolled Controlled
(lbs/year) (lbs/year)
Benzene
Toluene
Ethylbenzene
4960
4133
128
4960
154
7470
6225
193
7470
232
242
202
6
242
8
Xylene
3024
2520
78
3024
94
n -Hexane
42559
35466
1099
42559
1319
224 TMP
186
155
5
186
6
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-F
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 NSPS Kb
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not subject to NSPS 0000
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
Section 07 - Initial and Periodic Sampling and Testing Requirements
Does the company use the state default emissions factors to estimate emissions?
If yes, are the uncontrolled actual 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.
EIS
Does the company use a site specific emissions factor to estimate emissions?
ISI
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? 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 may be appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on 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 sampling
Section 08 - Technical Analysis Notes
Operator has connected condensate tank battery to a VRU such that, "Tank vapors are routed to a VRU which compresses the gas befcre it is sold into a pipeline. Any vapors not recaptured by the VRU
are routed to the Enclosed Combustors." Operator chose to conservatively permit this point based on 62% VRU downtime - per previcus conversation with operator (regarding separate point which was
permitted in the same fashion), was informed that this seemingly high downtime estimation is due to the fact that the VRU is part of a pilot project investigating the use of VRUs on storage tanks, and
they do not yet have a good idea of the actual downtime, but suspect that it will be much smaller than 62%. Seeing that the estimationi is on the conservative side, will approve as such.
NOTE: Operator used slightly different equation to calculate annual + requested heat release of waste gas (equation below). This gives more conservative NOx and CO estimates than the usual equation
used in this PA, so will approve of use.
Annual Heat Release (MMBtu/yr) = [Uncontrolled VOC (tpy)] ' [2000 lb/ton] ' [1/Gas MW] * [379.41 scf/Ib-mol] ' [1/(mol%VOC)J ' [Heat Co itent (Btu/scf)] * [1 MMBtu/Btu]
Where:
Gas MW = 14.564 lb/lb-mol (From ProMax)
mol%VOC = 55.564 mol% (From ProMax)
Heat Content = 2320 Btu/scf (From ProMax)
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point tt
001
SCC Code
4-04-003-11 Fixed Roof Tank. Condensate, working+breathing+lashing losses
Pollutant
PM 10
PM2.5
NOx
VOC
CO
Benzene
Toluene
Ethylbenzene
Xylene
n -Hexane
224 TMP
Uncontrolled
Emissions
Factor
0.00
0.00
0.28
32.4
0.55
0.08
0.12
0.00
0.05
0.69
0.00
Control% Units
O lb/1,000 gallons
O lb/1,000 gallons
O lb/1,000 gallons
96.9 lb/1,000 gallons
0.0 Ib/1,000 gallons
96.9 lb/1,000 gallons
96.9 Ib/1,000 gallons
96.9 lb/1,000 gallons
96.9 lb/1,000 gallons
96.9 lb/1,000 gallons
96.9 lb/1,000 gallons
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
condensate
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
throughput
3 of 7 K:\PA\2019\19WE04O9.CP1
Condensate Tank Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements
Source is in the Non-Attainnvnt Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. 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)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section II.D.3)?
You have indicated that source Is in the Non Attainment Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
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)? [r{
3. Are total facility uncontrolled VOC emissions greater than 2 TPY, NOx greater than S TPY or CO emissions greater than 10 TPY (Regulation 3, Part B Section II.D.2)?
Source requires a permit
Colorado Regulation 7, Section XII.C•F
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at an oil and gas exploration and production operation', natural gas compressor station 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
Section XII.C.2 - Emission Estimation Procedures
Section XII D - Emissions Control Requirements
Section XII.E - Monitoring
Section XII.F - Recordkeeping and Reporting
Colorado Regulation 7, Section XII.G
1. Is this storage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance area?
2. Is this storage tank located at a natural gas processing plant?
3. Does this storage tank exhibit "Flash" (e.g. storing non -stabilized liquids) emissions and have uncontrolled actual emissions greater than or equal to 2 tons aer year VOC?
Source Req
Go to next
Source Req
rYes Continue •'
Yes Continue-'
K Source is st
Yes
No
Storage Tank is not subject to Regulation 7, Section XII.G
Section XII.G.2 - Emissions Control Requirements
Section XII C.1 - General Requirements for Air Pollution Control Equipment - Prevention of Leakage
Section XII.C.2 - Emission Estimation Procedures
Colorado Regulation 7, Section XVII
1. Is this tank located at a transmission/storage facility?
2. Is this condensate storage tank' located at an oil and gas exploration and production operation , well production facility', natural gas compressor station' cr natural gas processing plant?
3. Is this condensate storage 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?
Tic
Yes
Yes
Yes
Storage tank is subject to Regulation 7, Section XVII, B. C.1 &
Section XVII.B - General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
No
Storage tank is subject to Regulation 7, Section XVII.C2
Section XViI.C.2 - Capture and Monitoring for Storage Tanks fitted with Air Pollution Control Equipment
40 CFR, Part 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels
1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters (m') ('472 BBLs]?
2. Does the storage vessel meet the following exemption in 60.111b(d)(4)?
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, cr treated prior to custody transfer2 as defined in 60.11lb?
3. Was this condensate storage tank constructed, reconstructed, or modified (see definitions 40 CFR, 60.2) after July 23, 1984?
4. Does the tank meet the definition of "storage vessel"' in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"' as defined in 60.111b?
6. Does 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 [`29.7 psi] and without emissions to the atmosphere (60.110b(d)(2))?; 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 35 kPa (63.11ob(b))?; or
c. The design capacity is greater than or equal to 75 M' [-472 BBL] but less than 151 m11-950 BBL] and stores a liquid with a maximum true vapor pressure' less than 15.0 kPa(60.110b(b))?
Yes
Yes
Continue - '
Storage Tar
Source is st
Continue • '
Go to then
Go to then
Source is st
Source is st
Go to then
Storage Tar
`Storage Tank is not subject to NSPS Kb
Subpart A General Provisions
§60.112b - Emissions Control Standards for VOC
§60.113b - Testing and Procedures
§60.115b - Reporting and Recordkeeping Requirements
§'60.116b Monitoring of Operations
40 CFR, Part 6Q Subpart OOOO, 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 August 23, 2011 and September 18, 2015?
3. Are potential VOC emissions' from the individual storage vessel greater than or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 603430?
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 63 Subpart HH?
(Storage Tank is not subject to NSPS 0000
Subpart A, General Provisions per §605425 Table 3
§603395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§60.5395(g) - Notification, Reporting and Recordkeeping Requirements
§603416(c) - Cover and Closed Vent System Monitoring Requirements
§60.5417 - Control Device Monitoring Requirements
[Note: If a storage vessel is previously determined to be subject to NSPS 0000 due to emissions above 6 tons per year VOC on the applicab lity determination date, it should remain subject to NSPS 0000 per 60.5365(e)(2) even if
potential VOC emissions drop below 6 tons per year)
40 CFR, Part 63, Subpart MACT HH, Oil and Gas Production Facilities
1. Is the storage tank located at an oil and natural gas production facility that meets either of the following criteria:
a. A facility that processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2j); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission anc storage source category or is delivered to a final end users (63.760(a)(3))?
2. Is the tank located at a facility that is major' for HAPs?
3. Does the tank meet the definition of "storage vessel"' in 63.761?
4. Does the tank meet the definition of "storage vessel with the potential for flash emissions"' per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
e>
No
No
No
Storage Tank is not sutler: to MACT HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
163.774 - Recordkeeping
§63.775 - Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review RACT requirements.
Disclaimer
T his document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations 1 his document is not
a rule or regulation. and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances This document does not change or substitute for any law, regulation.
or any other legally binding requirement and is not legally enforceable In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing regulations.
and Air Quality Control Commission regulations. the language of the statute or regulation will control The use of non -mandatory language such as "recommend." 'may.' 'should,' and 'can,' is intended to
describe APCD interpretations and recommendations Mandatory terminology such as "must" and 'required' are intended 'o desciibe controlling requirements under the terms of the Clean Air Act and Air
Quality Control Commission regulations, but this document does not establish legally binding requirements in and of itself
Continue - '
Storage Ta-
Storage Ta'
Continue
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
PDC Energy, Inc.
County AIRS ID
123
Plant AIRS ID
A041
Facility Name
_Fern
11 Sec HZ
History File Edit Date
6/5/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
POIN
T
AIRS
PERMIT
Description
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
I 0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0 0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
19WE0409
TK-1: Condensate Tanks (20 A 538 bbl ea)
5.3
999.2
10.5
29.2
5.3
31.0
10.5
0.9
New Point
002
GP07
LOAD -1: Condensate Loadout
0.9
173.1
1.8
2.5
0.9
10.0
1.8
0.1
New Point
003
GP02
ENG-1: Cummins G855. site rated 179 hp. SN: 25436759
10.2
3.3
46.1
0.2
1.7
1.2
3.5
0.2
New Point
004
GP02
ENG-2: Caterpillar G3306NA, site rated 138 hp, SN.
18.1
0.9
18.1
0.4
1.3
0.9
2.7
0.4
New Point
005
GP02
ENG-3: Caterpillar G3306NA, site rated 138 hp, SN:
18.1
0.9
18.1
0.4
1.3
0.9
2.7
0.4
New Point
006
GP02
ENG-4: Caterpillar G3306NA, site rated 138 hp, SN
18.1
0.9
18.1
0.4
1.3
0.9
2.7
0.4
New Point
007
GP02
ENG-5: Caterpillar G3306NA, site rated 138 hp. SN
18.1
0.9
18.1
0.4
1.3
0.9
2.7
0.4
New Point
008
GP02
ENG-6: Caterpillar G3406TA, site rated 276 hp, SN:
41.0
1.9
41.0
0.8
2.7
1.9
5.3
0.8
New Point
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
APEN Exepmt/Insignificants
0.0
0.0
XA
Ext. Combustion Sources
0.3
0.3
3.6
0.10
3,0
0.0
0.3
0.3
3.6
0.10
3.0
0.0
From APCD 102 Form
XA
Fugitives
0.30
0.0
0.30
0.0
From APCD 102 Form
XA
Produced Water Tanks
0.50
0.0
0.50
0.0
From APCD 102 Form
0.0
0.0
0.0
0.0
FACILITY TOTAL
0.3
0.3
0.0
0.0
133.4
1,182.0
0.0
174.8
34.5
0.3
0.3
0.0
0.0
19.4
48.6
0.0
34.9
3.8
VOC: Syn Minor (NANSR and OP)
NOx: Syn Minor (NANSR and OF')
CO: Syn Minor (PSD and OP)
HAPS: Syn Minor n -Hex & Total
HH: NA
7777: Area
Facility Total
0.0
0.0
0.0
0.0
129.8
1,181.1
0.0
171.8
34.4
0.0
0.01 0.0
0.0
15.8
47.7 '
0.0f
31.91
3.7
Excludes units exempt from
Permitted
(A) Change
in Permitted Emissions
0.0
0.0 0.0
0.0
15.8
47.7
0.0
31.9
Pubcom & modeling (not) required based
on (A change in emissions)
Total VOC Facility Emissions (point and fugitive
o) Change in Total Permitted VOC emissions (point and fugitive
48.6
Facility is eligible for GP02 because < 90
_Project emissions less than 25/50 tpy
47.7
Note 1
Note 2
Page 5of7
Printed 7/1/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
PDC Energy, Inc.
123
A041
Fern 11 Sec HZ
Emissions - uncontrolled
(lbs
per year)
POIN
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL
(tpy)
0
0
0
0
0
0
0
0
0
0
0
0
0.0
!Previous
FACILITY
TOTAL
001
19WE0409
TK-1:
Condensate
Tanks (20 A 538 bbl
ea)
4963
7477
242
3027
42587
186
29.2
002
GP07
LOAD
-1:
Condensate
Loadout
508
4412
2.5
003
GP02
ENG-1:
Cummins G855, site rated 179
hp. SN:
25436759
276
38
35
21
41
0.2
004
GP02
ENG-2:
Caterpillar G3306NA, site rated 138
hp, SN:
G6X090
746
28
26
16
31
0.4
005
GP02
ENG-3:
Caterpillar
G3306NA.
site rated
138
hp. SN:
G6X073
746
28
26
16
31
0.4
006
GP02
ENG-4: Caterpillar
G3306NA,
site rated
138
hp, SN: G6X073
746
28
26
16
31
0.4
007
GP02
ENG-5:
Caterpillar
G3306NA,
site rated
138
hp,
SN: G6X087
746
28
26
16
31
0.4
008
GP02
ENG-6: Caterpillar
G3406TA, site rated
276
hp,
SN:
CRE002
1438
50
47
28
55
0.8
0.0
0.0
0.0
0.0
0.0
APEN
Exepmt/Insignificants
0.0
XA
Ext. Combustion Sources
0.0
XA
Fugitives
12
12
11
11
13
0.0
XA
Produced Water Tanks
31
41
?
15
6
0.0
0.0
0.0
0.0
TOTAL (tpy)
2.3
0.1
0.1
2.8
3.7
0.1
1.5
23.5
0.1
0.1
0.0
0.0
34.4
*Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text: uncontrolled emissions < de minimus
6
19WE0409.CP1
7/1/2019
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
PDC Energy, Inc.
123
A041
Fern 11 Sec HZ
Emissions with
controls
(lbs
per year)
POIN
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL
(tPY)
0
0
0
0
0
0
0
0
0
0
0
0
0.0
'Previous FACILITY
TOTAL
001
19WE0409
TK-1:
Condensate Tanks
(20 @ 538
bbl
ea)
154
232
2
94
1320
f
0.9
002
GP07
LOAD
-1:
Condensate
Loadout
25
221
0.1
003
GP02
ENG-1:
Cummins G855, site rated 179
hp, SN:
25436759
276
38
35
21
41
0.2
004
GP02
ENG-2:
Caterpillar
G3306NA,
site rated 138
hp. SN:
G6X09q
746
28
26
16
31
0.4
005
GP02
ENG-3:
Caterpillar
G3306NA,
site rated 138
hp, SN:
G6X073
746
28
26
16
31
0.4
006
GP02
ENG-4: Caterpillar
G3306NA.
site rated 138
hp, SN:
G6X073
746
28
26
16
31
0.4
007
GP02
ENG-5: Caterpillar
G3306NA,
site rated 138
hp, SN:
G6X087
746
28
26
16
31
0.4
008
GP02
ENG-6:
Caterpillar
G3406TA, site rated
276 hp,
SN:
CRE002
1438
50
47
28
55
0.8
0.0
0.0
0.0
0.0
0.0
APEN Exepmt/Insignificants
0.0
XA
Ext. Combustion
Sources
0.0
XA
Fugitives
12
12
11
11
13
0.0
XA
Produced
Water Tanks
31
41
2
15
6
0.0
0.0
0.0
0.0
TOTAL (tpy)
2.3
0.1
0.1
0.1
0.1
0.0
0.0
0.8
0.1
0.0
0.0
0.0
3.7
7
19WE0409.CP1
7/1/2019
COLORADO
Air Pollution Control Division
Din. trncra of rHcallh £; Errs xon?r9ri
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0409
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
PDC Energy, Inc.
Fern 11 Sec HZ
123/A041
NWNW SEC 11 T5N R65W
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
Twenty (20) 538 barrel fixed
roof storage vessels used to
store condensate. Vessels
are connected via liquid
manifold.
Emissions from the storage vessels
are routed to a sales pipeline
through the use of a vapor recovery
unit (VRU). During VRU downtime,
emissions are routed to enclosed
combustor(s). The VRU has a
maximum of 62% annual downtime.
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to 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.Qov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 10
COLORADO
Air Pollution Control Division
T er..,i rt of rut rNal h�,� tn1-'7�?•1[
Dedicated to protecting and improving the health and environment of the people of Colorado
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 the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
more; (iii) does not complete construction within a reasonable time of the estimated
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
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
31.0
10.5
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 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.
7. 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.)
Page 2 of 10
COLORADO
Air Pollution Control Division
Denagmen? of Pty!?r Health f; c. rr`.rcmm��nc
Dedicated to protecting and improving the health and environment of the people of Colorado
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-1
001
Emissions from the storage vessels are
routed to a sales pipeline through the use
of a vapor recovery unit (VRU). During VRU
downtime, emissions are routed to enclosed
combustor(s). The VRU has a maximum of
62% annual downtime.
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
8. This source shall be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates shall be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK-1
001
Total Condensate
throughput
1,466,500 barrels
Condensate
throughput during
VRU downtime
909,230 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.
9. The owner or operator shall monitor and record VRU downtime on a daily basis. VRU downtime
shall be defined as times when emissions from the condensate storage vessels are routed to the
enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total condensate
throughput volume, and total condensate throughput volume during VRU downtime shall be
recorded on a monthly basis. The owner or operator must use monthly VRU downtime records,
monthly condensate throughput volume records, and the calculation methods established in
the Notes to Permit Holder to demonstrate compliance with the process and emission limits
specified in this permit.
STATE AND FEDERAL REGULATORY REQUIREMENTS
10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
shall be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
Page 3 of 10
COLORADO
Air Pollution Control Division
L:e pa'Y»un[ of tn.U:a Health h F!�r
Dedicated to protecting and improving the health and environment of the people of Colorado
11. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
12. This source is subject to Regulation Number 7, 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)
13. 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;
• All combustion devices installed before May 1, 2014, must be equipped with an
operational auto -igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The storage tank covered by this permit 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.
15. 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
16. Upon startup of these points, the owner or operator shall follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3,
Part B, Section III.G.7.)
Page 4 of 10
COLORADO
Air Pollution Control Division
ns=trn nr of Ti b'.ic Halth FjE7 C3nir#A'1C
Dedicated to protecting and improving the health and environment of the people of Colorado
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. 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
18. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice (APEN) 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
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less, above the
level reported on the last APEN submitted to the Division.
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
• No later than 30 days before the existing APEN expires.
GENERAL TERMS AND CONDITIONS
20. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Page 5 of 10
COLORADO
Air Pollution Control Division
T in tment of rib c Health £t Fnc t- not'ot
Dedicated to protecting and improving the health and environment of the people of Colorado
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
23. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Page 6 of 10
By:
COLORADO
Air Pollution Control Division
UN -,p t r cnr of r• b.ic Hr' ith s• [n.+r3nmeTx
Dedicated to protecting and improving the health and environment of the people of Colorado
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Page 7 of 10
COLORADO
Air Pollution Control Division
Deprhncnz n€ rub Healh ft Err.^r..�et?r>;[
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 shall 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 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
4,960
154
Toluene
108883
7,470
232
Ethylbenzene
100414
242
8
Xylenes
1330207
3,024
94
n -Hexane
110543
42,559
1,319
2,2,4-
Trimethylpentane
540841
186
6
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.
Page 8 of 10
COLORADO
Air Pollution Control Division
Dore rnnrnr n` Pub' r H°alth £r Fnv>+.:.nrriayc
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission
Factors
(lb/bbl)
Controlled
Emission Factors
(During VRU
Downtime)
(lb/bbl)
Controlled
Emission
Factors (During
VRU Uptime)
(lb/bbl)
Source
NOx
0.0116
0.0116
0.0
TCEQ
CO
0.0231
0.0231
0.0
VOC
1.3628
0.0681
0.0
ProMax
71432
Benzene
0.0034
0.0002
0.0
108883
Toluene
0.0051
0.0003
0.0
1330207
Xylene
0.0021
0.0001
0.0
110543
n -Hexane
0.0290
0.0015
0.0
Note: The controlled emissions factors for this point are based on a control efficiency of 100% when
emissions are routed to the VRU and a control efficiency of 95% when emissions are routed to the
enclosed combustor(s) during VRU downtime. The site specific emission factors for this source
were developed using a site specific pressurized liquid sample in conjunction with ProMax. The
pressurized liquid sample was obtained from the outlet of the HLP separators on 03/12/2019.
The sample temperature and pressure are 105°F and 27.2 psig respectively. Uncontrolled actual
VOC and HAP emissions are calculated by multiplying the emission factors in the table above by
the total condensate throughput. Controlled actual VOC and HAP emissions are calculated by
multiplying uncontrolled emissions by a 100% control efficiency when emissions are routed to the
VRU and a 95% control efficiency when emissions are routed to the enclosed combustor(s) during
VRU downtime. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO
emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were
converted to units of lb/bbl using permitted annual NOx and CO emissions (lb/yr) and condensate
throughput (bbl/yr) during VRU downtime. Actual NOx and CO emissions are calculated by
multiplying the emission factors in the table above by the total condensate throughput during
VRU downtime.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN 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.
Page 9 of 10
COLORADO
Air Pollution Control Division
Dc,rvt,tincnr of ri.h'`r Health 'it En,ltanin,nf
Dedicated to protecting and improving the health and environment of the people of Colorado
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC, CO, NOx, n -Hexane, Total HAPs
NANSR
Synthetic Minor Source of:
VOC, CO, NOx
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
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 10 of 10
APR - 5 2019
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 loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website at: www.colorado.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.
Permit Number:
1' 1 km O0 AIRS ID Number: t 23 /f "r k" 00\
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Fern 11 Sec HZ
Site Location: NWNW Sec 11 T5N R65W
Mailing Address:
(Include Zip Code) 1775 Sherman Street, Suite 3000
Denver, CO 80203
Site Location
County: Weld
NAICS or SIC Code: 1311
Contact Person:
Phone Number:
E -Mail Address2:
Jack Starr
(303) 860-5800
Jack.Starr@pdce.com
1 Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that will appear
on all documents issued by the APCD. Any changes will require additional paperwork.
2 Permits, exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 1 I A.
COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit k 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
❑ GP01 O GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR -
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment O Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
- OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info a Notes: Initial Construction Permit request for condensate storage tanks at a new facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 01/07/2019
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7 days/week 52
Storage tank(s) located at:
Exploration Et Production (EEtP) site
weeks/year
❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
SI
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
p
Yes
■
No
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
•
Yes
•
No
If "yes", identify the stock tank gas -to -oil ratio:
0.00255
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
■
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limits
(bbl/year)
Condensate Throughput:
1,222,084
From what year is the actual annual amount?
Projected
Average API gravity of sales oil: 50.8 degrees
❑ Internal floating roof
Tank design: ✓❑ Fixed roof
1,466, 500
RVP of sales oil: 9.4
❑ 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
20
10,760
3/2018
1/2019
Wells Serviced by this Storage Tank or Tank Battery6 (E£tP Sites On
y)
API Number
Name of Well
Newly Reported Well
05
- 123
- 44586
Fern 11U-204
II
05
- 123
- 44580
Fern 11 U-334
SI
05
- 123
- 44579
Fern 11U-434
El
05
- 123
- 44584
Fern 11V-204
El
05
- 123
- 44585
Fern 11V-214
SI
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 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)
40.420591 / -104.637625
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
N/A
Indicate the direction of the stack outlet: (check one)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
El Circular
❑ Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
COLORADO
Form APCD-2O5 - Condensate Storage Tank(s) APEN - Revision 7/2O18
Permit Number: AIRS ID Number:
[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.
Pollutants Controlled: VOC & HAPs
Vapor
❑✓ Recovery
Unit (VRU):
Size:
Make/Model: Flogistix Compressor
Requested Control Efficiency: 100
VRU Downtime or Bypassed (emissions vented): 62
❑ Combustion
Device:
Pollutants Controlled: VOC & HAPs
Rating: MMBtu/hr
10 x Cimarron 48", 1 x Cimarron 60"
Type: Enclosed Combustors Make/Model:
Requested Control Efficiency: 95
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Waste Gas Heat Content:
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
Btu/scf
MMBtu/hr
❑ Closed Loop System
Description of the closed loop system:
❑ Other:
Pollutants Controlled:
Description:
Control Efficiency Requested:
Section 7 - Gas/Liquids Separation Technology Information (E£tP 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) APEN - Revision 7/2018 4
AV COLORADO
wtT. A�.���� �:�:.
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustors and Tank VRU
96.90%
NOx
CO
HAPs
Enclosed Combustors and Tank VRU
96.90
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc) )
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions8
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
1.3628
lb/bbl
ProMax
832.70
25.81
999.24
30.98
NOx
0.1380
Ib/MMBtu
TCEQ
N/A
4.38
N/A
5.25
CO
0.2755
lb/MMBtu
TCEQ
N/A
8.74
N/A
10.49
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor7
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc)
Uncontrolled
Emissions
(Pounds/year)
Controlled
Emissions8
(Pounds/year)
Benzene
71432
0.0034
lb/bbl
ProMax
4,132.55
128.11
Toluene
108883
0.0051
lb/bbl
ProMax
6,224.54
192.96
Ethylbenzene
100414
0.0002
lb/bbl
ProMax
201.30 (DM)
6.24 (DM)
Xylene
1330207
0.0021
lb/bbl
ProMax
2,520.03
78.12
n -Hexane
110543
0.0290
lb/bbl
ProMax
35,465.30
1,099.42
2,2,4-
Trimethylpentane
540841
0.0001
lb/bbl
ProMax
155.16 (DM)
4.81 (DM)
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
7 Attach condensate liquid laboratory analysis, stack test results, and associated emissions calculations if you are requesting site
specific emissions factors according to the guidance in PS Memo 14-03.
8 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
o
COLORADO
5 E,„
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 9 - Applicant Certification
I hereby certify that all information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
S
Sig .&re of Legally Authorized Person (not a vendor or consultant)
Jack Starr
Date
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 $191.13 and the General Permit
registration fee of $312.50, if applicable, to:
Colorado Department of Public Health and Environment
Air Pollution Control Division
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Make check payable to:
Colorado Department of Public Health and Environment
For more information or assistance call:
Small Business Assistance Program
(303) 692-3175 or (303) 692-3148
APCD Main Phone Number
(303) 692-3150
Or visit the APCD website at:
https://www.colorado.gov/cdphe/apcd
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018 6 I alik
COLORADO
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml
Company Name:
PDC Energy, Inc.
Source Name:
Fern 11 Sec HZ
Emissions Source AIRS ID2:
E 11) /A (64-@/ 60 t
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 -123 - 44582
Fern 11V-234
/1
05 - 123 - 44581
Fern 11V-304
/1
05 - 123 - 44588
Fern 11V-334
/1
05-123-44583
Fern 11W-214
/1
05 - 123 - 44587
Fern 11W-314
►1
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
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
Hello