HomeMy WebLinkAbout20192506.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
1150 O St
PO Box 758
Greeley, CO 80632
June 26, 2019
Dear Sir or Madam:
RECEIVED
JUL 012019
WELD COUNTY
COMMISSIONERS
On June 27, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Barr 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.
Colorado Dept. of Public Health Et 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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2019-2506
Air Pollution Control Division
Notice of a Proposed Project or Activity
Warranting Public Comment
Website Title: PDC Energy, Inc. - Barr 11 Sec HZ - Weld County
Notice Period Begins: June 27, 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: Barr 11 Sec HZ
Oil &t Natural Gas Production &t Processing
SESE Quadrant of Section 11, Township 5N, Range 64W
Weld County
The proposed project or activity is as follows: The Barr 11 Sec HZ is a new facility with
twelve (12) newly -drilled wells. A commingled liquid stream (containing natural gas,
condensate and produced water) flows from twelve (12) wells, through one (1) of twelve (12)
heated separators each with a 0.750 MMBtu/hr burner. In the separators the fluids are
separated into individual phases (natural gas, produced water, hydrocarbon liquid).
The hydrocarbon liquid (condensate) exists the separators and flows to twenty-four (24) 538
bbl condensate storage tanks. This facility utilizes two (2) different kinds of emission control
devices for the condensate storage tanks; Enclosed Combustors and Vapor Recovery Units
(VRUs). Tank vapors are routed to a VRU which compresses the gas before it is sold into a
pipeline. Any vapors not recaptured by the VRU are sent to the Enclosed Combustors.
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
19WEO104.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
COLORA00
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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 wilt 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
COLORADO
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COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Permit number:
Date issued:
Issued to:
CONSTRUCTION PERMIT
19WE0104
PDC Energy, Inc.
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance:
1
Barr 11 Sec HZ
123/A025
SESE Quadrant of Section 11, 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
Twenty -Four (24)
538 barrel fixed roof
storage vessels used
to store condensate
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 63.9% 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.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
Page 1 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
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
NO.
VOC
CO
TK-1
001
9.1
71.4.
18.1
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant 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.
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.)
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
63.9% 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
1,000,700 barrels
Condensate throughput during
VRU downtime.
639,447 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.
Page 3 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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)
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.
Page 4 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
OPERATING £t 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.)
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
orother 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 (NOX) in ozone
nonattainment areas emitting less than 100 tons of VOC or NOX per year, a change in
annual actual emissions of one (1) ton per year or more or five percent, whichever is
greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions of five
percent or 50 tons per year or more, whichever is less, above the level reported on the
last APEN submitted; 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.
Page 5 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Whenever there is a change in the owner or operator of any facility, process, or activity;
or
• Whenever new control equipment is installed, or whenever a different type of control
equipment replaces an existing type of control equipment; or
• Whenever a permit limitation must be modified; or
No later than 30 days before the existing APEN expires.
20. 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).
With respect to this Condition, Part D requirements may apply to future modifications if
emission limits are modified to equal or exceed the following threshold levels:
Permit
Number
AIRS
Point
Equipment
Pollutant
Emissions (tpy)
Threshold
Current
Permit
Limit
Description
19WE0104.CP1
001
Condensate Storage
VOC
100.0
(NANSR)
71.3
GP07
002
Loadout
VOC
10.0
GP02
003
RICE
VOC
1.4
PQ2
004
RICE
VOC
0.9
GP02
005
RICE
VOC
1.2
GP02
006
RICE
VOC
1.9
19WE0186.CP1
001
Condensate Storage
NOx
100.0
(NANSR)
9.1
GP07
002
Loadout
NOx
0.5
GP02
003
RICE
NOx
2.0
GP02
004
RICE
NOx
1.3
GP02
005
RICE
NOx
1.7
GP02
006
RICE
NOx
2.7
Page 6 of 11
COLORADO
Air Pollution Control Division
Department of Pubilc Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
21. This permit and any attachments must be retained and made available for inspection upon
request. The permit may be reissued to a new owner by the APCD as provided in AQCC
Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the
submittal of a revised APEN and the required fee.
22. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does not
provide "final" authority for this activity or operation of this source. Final authorization of the
permit must be secured from the APCD in writing in accordance with the provisions of 25-7-
114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization
cannot be granted until the operation or activity commences and has been verified by the APCD
as conforming in all respects with the conditions of the permit. Once self -certification of all
points has been reviewed and approved by the Division, it will provide written documentation
of such final authorization. Details for obtaining final authorization to operate are located
in the Requirements to Self -Certify for Final Authorization section of this permit.
23. This permit is issued in reliance upon the accuracy and completeness ofinformation supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
24. Unless specifically stated otherwise, the general and specific conditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25.7-114.5(7)(a), C.R.S.
25. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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.
26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued, the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
Page 7 of 11
COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By: DRAFT
James Ricci
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc. for condensate
storage tanks at a synthetic minor facility
located in the non -attainment area.
Page 8 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder 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 shallnotify 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-reps
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
9792
313
Toluene
108883
13035
416
Ethylbenzene
100414
395
13
Xylenes
1330207
4700
150
n -Hexane
110543
84932
2714
2,2,4-Trimethylpentane
540841
295
9
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 9 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
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
lb/bbl
Source
NOx
1.61 x 10-2
TNRCC Flare
Guidance
CO
3.22 x 10-2
VOC
4.47 x 10°
1.43 x 10-1
ProMax 4.0
with site
specific
71432
Benzene
9.78 x 10"3
3.13 x 10-4
108883
Toluene
1.30 x 10-2
4.16 x 10-4
100414
Ethylbenzene
3.95 x 10-4
1.26 x 10-5
1330207
Xylene
4.70 x 10"3
1.50 x 10"4
pressurized
110543
n -Hexane
8.49 x 10-2
2.71 x 10-3
liquid, input
540841
2,2,4-Trimethylpentane
2.95 x 10"4
9.42 x 10-6
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. 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 cornbustor(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 a GOR of 45.33 scf/bbl
and a heat content of 2580 Btu/scf. 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.
8) This facility is classified as follows:
Page 10 of 11
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, NOx, n -Hexane, Total HAP
NANSR
Synthetic Minor Source of: VOC, 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
Appendix A - Appendix I
NSPS
Part 60, Appendixes
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 11 of 11
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer
Package
Received Date
Review Start Date
t,3rmeiCec
3�8�9635
%?6/201.
l4/4/2019"
Section 01- Facility Information
Company Name
County AIRS ID
Plant AIRS ID
Facility Name BerrUSecF Z
Location SESE Quadrant of Section 11, Township 5N Range 64W
County Weld County ,
Typef l0 It7 opu~& aid p eiF q YP Facility ?p dnn,,.aq �.<„s
What industry segment? 1 'Na tural Gil"grbio & P
Is this facility located in a NAAQS non attainment area?
If yes, for what pollutant? ❑ Carbon Monowde (CO)
Section 02 - Emissions Units In Permit Application
Particulate Metter (PM)
Quadrant
2 Ozone (NOx &VOC)
Section
Township
Range
E�5
64"
AIRS Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
001" -
x�
one eq a
)n"wr
es�
t�9
1 E0104^CPT
"�.��
�e
9L�vs`Mlssuancer�`
a
� � 4, ,
r
' ,
4,—ii—Wet
4
Waite_
�' �Ek ` 6 =„
,l-n�� r���
Section 03 - Description of Project
fv *�„ ccH Z 3 fV r)ariewfa^.dw
The sariel Sec is a n;#a i � d twe e�121 newly drilled wells-^ �„r=` r �^ � � � a;i;::, •„: „ih�F
����r C„,"wi.� ;"' wns x,�F ,� �`^ w 4� � �5 � :5�t�w iH k4 mss" rN Kr 'y "` rr`•i.., qei
�"' " F e*�.�'r� £"f � '. •I,I{:,..'M M��L�
k 2'2' -.onS"�➢nsat"e7F£ "Y flow fr Atwi SC° e`r ors
eac
{ Acom{ mgled�gwdstream(contai innaturalgas, orlde sa ea dproducedwatet)f[owsfronittwel a 12 well,thtou'�64�bi(`e,,(Sj'bftvtalve 42),heatedsepar�se' ��Fz
a 0,750 ' Btu hrb �a u,o ,- pn r P ' - p u ig in Water, y ` kxkd
r er ey a aia the f ends arese orated into individual` hoses na4U, -- . ( used water hydiocartion
�����rl'�'�#�,�:4r�„�-"'`` ��.__ ��." ""�"', �rw<;•^,,.,,��.}�
The ydrocabo liquid to de sa a iststheseparator an fl•wstotwegtyfodr(z,`453 „ co den satelstoragetariksThisfacility utilaestvp(2)diffett,A sofemisTsioncontr9i evicn
�sq " ' `b o cove lJ is V Us a � y r `forthecondepsa�estorageta�ik�3 Enclas�dC�ombusto r>�d- a�e,_ uy n,� ( R �7 n vaporaareroutedtaaYRUwfixhcompressesth gasbefa eibf,�sadiiitoapipehna Any o_
"vc
nopreca tured>?ythe�VRUaresenMt ,=Egclp�5edCo us o-`
•
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why?
fz" Yds
e uestiris nth ti moYP
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary
tT�
'N4
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non Attainment New Source Review (NANSR)
Is this stationary source a major source?
If yes explain what programs and which pollutants here
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non Attainment New Source Review (NANSR)
�lpe3�+n
502 NOx
CO VOC
SO2 NOx CO VOC
8- ❑
PM2 S PM10 TSP HAPs
TSP
HAPs
PM2 5 PM10
El
-❑ ❑
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123
County
A025
Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Requested Overall VOC & HAP Control
Efficiency %:
Twenty-four (24) 538 bbl fixed roof condensate storage tanks
VRU with 62% Downtime and Enclosed Combustors ( 12 x 48" and 1 x 60" Cimarron)
361,252.7 bbls at 100% Control (36.1% of throughput to VRU) +
639,447.3 bbls at 95% Control (VRU bypassed throughput to Enclosed Combustor)
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput =
PTE Condensate Throughput =
1,000,700
1,000,700
1,000, 700
Barrels (bbl) per year
Barrels (bbl) per year
Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas = 2580 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced = scf/bbl
Actual heat content of waste gas routed to combustion device =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) Feat content of waste gas routed to combustion device =
Section 04 - Emissions Factors & Methodologies
Will this storage tank emit flash emissions?
117,048
74,794
131,302
131,302
Actual Condensate Throughput While Emissions Controls Operating =
1,000,700
Requested Monthly Throughput = 84991 Barrels (bbl) per month
From ProMax (Weighted average of Flash and W&B)
MMBTU per year
MMBTU per year
MMBTU per year
MMBTU per year
Emission Factors
Condensate Tank
Emission Factor Source
Uncontrolled Controlled
Pollutant
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
4.47E+00
1.43E-01
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 EF. (includes flash)
Site Specific E.F. (includes flash)
Site Specific E.F. (includes flash)
Benzene
9.78E-03
3.13E-04
Toluene
1.30E-02
4.16E-04
Ethylbenzene
3.95E-04
1.26E-05
Xylene
4.70E-03
1.50E-04
n -Hexane
8.49E-02
2.71E-03
224 TMP
2.95E-04
9.42E-06
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM10
7.45E-03
8.72E-04
AP -42 Table 1.4-2 (PM1O/PM.2.S)
AP -42 Table 1.4-2 (PM1O/PM.2.5)
TNRCC Flare Emissions Guidance (NOx)
TNRCC Flare Emissions Guidance (CO)
PM2.5
7.45E-03
8.72E-04
NOx
1.38E-01
1.61E-02
CO
2.76E-01
3.22E-02
Section 05 - Emissions Inventory
From ProMax (Flash + W&B)
From ProMax (Based on the 2 value above)
36.1% of throughput sent to VRU
From Applicant
Flash (lb/bbl)
W&B (lb/bbl)
4.003651247
0.4647868
0.009106653
0.000678045
0.012070014
0.000956028
0.000363336
3.13794E-05
0.004216889
0.000479516
0.076348823
0.008523856
0.000265866
2.88883E-05
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
2235.8
2235.8
71.4
2235.8
71.4
12134
0.5
0.4
0.4
0.5
0.5
83
0.5
0.4
0.4
0.5
0.5
83
9.1
8.1
8.1
9.1
9.1
1539
18.1
16.1
16.1
18.1
18.1
3072
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
Xylene
9792
9792
313
9792
313
13035
13035
416
13035
416
395
395
13
395
13
4700
4700
150
4700
150
n -Hexane
84932
34932
2714
84932
2714
224 TMP
295
295
9
295
9
Section 06 - Regulatory Summary Analysis
Barrels (bbl) per year
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 OOOO
Storage Tank is not subject to NSPS OOOO
Regulation 8, Part E, MACT Subpart HH
Storage Tank is not subject to MACT HH
(See regulatory applicability worksheet for detailed analysis)
2 of 5
K:\PA\2019\19W E0104.CP1.xlsm
Condensate Storage Tank(s) Emissions Inventory
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.
NA.
Does the company use a site specific emissions factor to estimate emissions?
Yes
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.
i
t.
r
5:
Yes
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
A pressurized liquid sample was taken on 1/22/2019 at the Barr II sec Pad Site, Unit ID Barr 3N. The sample was taken by Air Pollution Testing, Inc at a Probe Temp of 99 deg F and a Probe Pressure of 26.1
psig. An Extended Natural Gas Liquid Analysis was provided by the applicant that listed the components and the respective Mole % of this sample. This data was input into ProMax 4.0 to estimate both
Flash and W&B losses.
The secondary combustion emissions were calculated using the estimated Vapor Volumetric Flow and the Gross Heating Value, both from ProMax. The applicant estimated heat content using the
following equation. This was accepted since it resulted in a more conservative value then the ProMax model.
Flash Gas ('�'Nst") — Uncontrolled VOC \t"") x 2000 ( tom, x x 379.41 SCF Gas x ( ' o } x Heat Content Btu x 1 /,� mstul
yr yr tort Gas .MW lh•mol voc ,y SCF J) 10 Btu
NOS received 6/11/2019 11:45:22 AM
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Point #
001
Process #
01
SCC Code
4-04-003-11 Fixed Roof Tank, Condensate, working+breathing+flashing losses
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.02 0 Ib/1,000 gallons condensate throughput
PM2.5 0.02 0 lb/1,000 gallons condensate throughput
NOx 0.43 0 lb/1,000 gallons condensate throughput
VOC 106.4 97 lb/1,000 gallons condensate throughput
CO 0.86 0 Ib/1,000 gallons condensate throughput
Benzene 0.23 97 lb/1,000 gallons condensate throughput
Toluene 0.31 97 Ib/1,000 gallons condensate throughput
Ethylbenzene 0.01 97 lb/1,000 gallons condensate throughput
Xylene 0.11 97 lb/1,000 gallons condensate throughput
n -Hexane 2.02 97 lb/1,000 gallons condensate throughput
224 TMP 0.01 97 Ib/1,000 gallons condensate throughput
3 of 5 K:\PA\2019\19WE0104.CP1.xlsm
Condensate Tank Regulatory Analysis Worksheet
lb.. Is. the No.Atmmme m Area
ATTAINMENT
1, Areuncontrelldactual enlsaons from any umerfa pnoutan.rmm thrsmmvldual source greaterthan TV((Regulatln 3, Pan A, Seelan ll.0.1.,1?
InfEer to a6 p datelp,.12/30/2[02 77/,1/2[0z(SeePSMemo05..Derinklor.@.2andla0and.sedion foral.onalg.tlanceangrandfatherapppra Ntm?
3. Ares
[You haw trHig„adolutmurmmm ismthe Non.MtaiemArea n<M1an voTPYnmemniom ¢rarertnanloTlanon3, pan,,,saunn [.
1. ,PY (Regmation3, Pan A, sealnnll.o.3.lx
ss.so^,,nw d.m�Qn:&ra)..o12/3oh0az and net mold�HN:Mr a/31/2om(see-01.nglons1.12 andsaoand sane forad...lg....en grandfatherapplieabtlnm?
3. Ant unwnre m„ mgrea.rthanx PI, great..any,PYmine..Insgrea°erthana[T.,(Regulation3, Part e,sedfonll.o.xn
b nom reaapalmlt
1. s thIsstorage.nk.tom re e3-hro a anment/1 me
2. Isthis storage tank located land gasexploradprdun apaum on,turalwssanpam sorstatton or tural¢as ddpsmtlon?
3. Is [Ns sto.geta.located up
stream pi gas oe.smg plant?
I bneaea tank n swie. m peemmron 7. semen 8II.o4
Control Repmrements
Sadlnxg.4-n alydkaepwgad Renonmg
sto.ge tank located h6 -fl 3431411214116 orany ozone nm.analnmema,a orattanmat/marnnnceasa,
IstlYsatoragatalk...el at a natural gas pmmzdngppm?
3. Ooesths .61661Flas6"le...to.gnon-stabilized lrnwdsl emiuncontrolledrs w pm and have uncontrolled actual emtsbgreatertlancualto3 tens pcvmrva?
I.oracaTs.fsnotsuble. to geRwatlon?,sucgonnge
Section snn, Raulremenn
-General peeulrements forptrpnllution control Equipment -Prevent. of Leakage
Section KII.C.2 —EmIssfon Estimation Prom,.
Colorado egulauon7,b.longvll
1. Is thls tank located. a mo6sto l
ondem a3fl8 ft t21 an and gas exploration and pmdu..a operation , nprdu.lm famavz,natual gas eon.re,orstatlon or natural gas pre'a Ion plant?
3. Is thls a fixed roof storage lank,
a. Are...trolled
actual ernIsstor.4of noragetankba..twpeeulation7.5e�nnrvll.eual �e1t$ 3na onset varvaq
sadion.II.6 —General zpnsCo..,oand onAn'ngfons lMPollution Control
Ffvdp e
-Fml
eoulrentents
5. Does the ondersatenpnge ankcontam onfestablllad"1lquds? khaulAste to SadlonxVl x -Coo urreadM [trod .fors aageTan.find wnhAlrpollutlonmmrd Equlpmem
cIP
<Ion of
1. 1s t6elndMdualstongevasel apa1Ngreate.bn ormualw 75... meet Imall 72 eetsR
2. hemllowrn¢811118on MO112d(d((91?
a. Does 1.7..4 has 4252721 ..1Mless than nrequal.1,560579 5415400334 used for ....urn' mMen.testeretl.p.ossdortreatd pdortot.todvtansier'as defined .60.11142
a, t,s emdensate rtnageta hk ennstru.d, rearm..., or mdlfid ,see tlefin lllons 90 aR, 6011 A..517 23.1924?
9. Does theta,. hedefInmonnr•atgragew„el° 12
a `vdatlkarsnlelgus IV0Li'asb s. Dots thestonge vesstl eddndln 60211.
oo eofahefnhowing additional aemptpa:
a. la tha e Pa 1ze mead wham anssioamrM1exmnµere 1O.1O6(d1441010.
b. The .. mapawsscbyls Areaet rt anssorequalro 52m'Ce50Flet]...oresa...with a...hum tmevapmgrasurea lac than aslwa13011041011,or
IThenOalg., vac. se grearemhan or equal to75 M'I'a7x e3tl6ut1asilk��alma('es[eey.eta.oiaallquMwghammrmwntneaporpresure`lac Nan 15.0554150.2206@1)1
Go ned Men
8.11Y41.1
ints
You Have ndimtedtM site attalmnemsmws on the prole. summary she..
Continue -You have lndlmted the fadlity.oson thepnle't summary sheet.
s oub adllry attalmm�t status on lhePmse Sunman/sheet.
No StongeTank et
YeSdeterminedo Regulation 7, Scdonxil.S You havexdimtd fad., tvpeon project summary sheet.
m reels suble.
irehtfarce
Sourcessub.. to parts of Re.lat.17,sectronsxlgl.e&C Soto the fiat queen
.+a']souaeis subject pszn.ons e¢u e37,sectlo3 xal, subsections B 23
Go to the next puestIon
stn,geTank s not sub.. N5P5x6.
.c,"Viteg,
kvwx
40.11x6-FmssIons Control Standards forVOC
§60.113b-T.tmpand Procedures
4poassh-fmnnrng andpemnfNenrngRwulrements
460.336b -Mottoes of0peraHns
ata fad./ then..re ml and natualgaz pmiutlon segment, natural gas pmassingsegmemarnaural gas transmission and maagesegmentof4h61dmtry?
2. Was this condarmte con.rtmed, reconstructed,edlw nee
he0.zi6ewnA ¢ rt 3,2011.[ sepem6.16,20ssx
tlmlrt ngevessel seat. nmw than 'Iar, to6 tons vear?
a. Mies tWs condemn. vessetlmeet thedefrnttrono ,torage"sssel"',60.5a3[?
5, Isthenoraa,ev.sel staged to ad controlled In accordance.. olremens for.. vesselstnOaR Part O tub anxbn 00CFR Part6350 xx?
Subpart A, General ProvIslons #615603425 Table3
00.5395 -Emissions control standards fo1401
40,5913-Testingare Procedures
564.5.5181-Notlflatfor, Reportingad Reodkeeping Require...
460.541610 -Cover and pare Vent.... MONtodng Requirements
4O.s917-Conned Dew. Mnitedng Regw7nems
Note: I to POPS 0000 due m emission above 6e pa ye n VOC vp hnlry du rm,nn on date, shod:, rumen I to NSP5 0000 per 6o53651a1(2leven
p oral VOcer..lon drop bylaws per yearly
90 RR. Part 53,5apart MAC. M. Oil and Gas Prochnion ROW.
1. Isthes a6484a a 451241gag
a dunn/884/7115 meeneltneroftbeldkvru,g.meta:
a. AfuigNslut puexses,uarndes ornark hydrocarbon Rwkle 163.7601,11:11:OR
vthatp uralmeorinta the pclm at whldt natural gas ernes thentural gas Innsmssion and storagesoumemtegcrvor u delivered to a final end user. 1Ta.xa4Pl011?
2. Inheta 22mtd at a fadlltvtbat14umaprfor HAPsss? m
3. m the tank meet the dein.= of,tdrage wsers. 63.761,
9. 0cnthetank matthe clefintlnn of 'storage vessel.. .p.m.! fornashunsslns'w 61?
5. I,thelank subeutton2 IS renuo-ements under..cmParts[.su6 rtgh orsolart 0000x
ISebnwTanklz net subject to VIALTNN
54 2a(Table
453.766 -.Won, Control Standab:
463.773-Manitaring
453.776-Rc
463,775-Rro41o1176teg
Th. document assids operators.. determining applied,. ye` erlam regvirem.t. or clenRRAc{is impl87,412ng185215 nns,30241Ouairy canna cwnmssien mdulahwls. Thla documanl
14571 anus repletionorriagnon, andg78 asis', contains may not apply to a particular
ular 511240n based upon the ...Pal.. and cacumc1ancus. Tr. dcumenl does not change msubsnWle fir an
y N binding requirement.nd is not legally .Ere. In the event crony cdn7Ac(Wive. the langua64071714 Occumen1 and the language of the clean AirTAc1, any
Impknlenting reputations, and ph quality Contra, Commiseion regulations, M Me...9e the smwam or regd.. Wee.l Tanon-mandatory language such as hasom1874'hney;
'shove;71and 711'cen,'Is intended. describe APCO lntersietations and recommendations Mandalay terminology..as'nwsY and're?uiredare intend..describe conlraNiyregti .incurs under
the terms of the Channel., end Av Quality Control Commission regulations, but the document does not entahlish legally binding redden.. in and of itself
contlnue-You Have InclIcalecl the sourcacategoryonhe Prg211141 912 she.
amsu geiank Is not N5Ps0000-This nkvas constructed w¢Ideoltheappkabillrydata.
Iny ILorue You havemdmtdthe soureemtegaryonthe Proletsummar,sheet.
4 x{413
Man ee
toageTank s not sub.tMACT HH-There are no MACTHH regoremants fortanks at area mum
RECEfV`
Condensate Storage Tank(s) APEN JAN 3 0 2019
Form APCD-205 sx IPpory
oCD
QOUretb
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.Rov/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: l "a E G t OAr
AIRS ID Number: 123 /Pt O25/ 001
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Barr 11 Sec HZ
Site Location: SESE Sec 11 T5N R64W
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
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
�ViCOLORADO
1 I DR.,�Fn: m P:t�.rc
1,3131 _ ,vlranrricr:l
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 2 - Requested Action
❑✓ NEW permit OR newly -reported emission source
❑✓ Request coverage under traditional construction permit
0 Request coverage under a General Permit
0 GP01 ❑ GPO8
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)
0 Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership' ❑ 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 Et Notes: Initial permit request for condensate storage tanks at a new facility
3 For company name change, a completed Company Name Change Certification Form (Form APCD-106) must be submitted.
4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104) must be submitted.
Section 3 - General Information
General description of equipment and purpose: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 10/31/2018
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24 hours/day 7
days/week
52
weeks/year
Storage tank(s) located at: ❑✓ Exploration a Production (HIP) site ❑ Midstream or Downstream (non EEtP) site
Will this equipment be operated in any NAAQS nonattainment area?
0
Yes
■
No
Are Flash Emissions anticipated from these storage tanks?
•
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:
0.0081
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)
805 series rules? If so, submit Form APCD-105.
Yes
No
Fi
■
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
0
■
Form APCD-205 - Condensate Storage Tank(s) APEN! - Revision 7/2018
• Ay COLORADO
2 I r ErwermenznI
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:
1,000,700
1,000,700
From what year is the actual annual amount?
Projected
Average API gravity of sales oil: 51.3 degrees
❑ Internal floating roof
Tank design: ❑✓ Fixed roof
RVP of sales oil: 9.7
❑ 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
24
12,912
4/2018
10/2018
Wells Serviced by this Storage Tank or Tank Battery6 (MP Sites Only)
API Number
Name of Well
Newly Reported Well
05
- 123
- 45681
Barr 111-221
GI
05
- 123
- 45687
Barr 111-301
12
05
- 123
- 45692.
Barr 11 L-201
l9
05
- 123
- 45683
Barr 11L-221
SI
05
- 123
- 45682
Barr 11L 301
12
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EEtP 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)
40.407311 / -104.622989
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)
❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
❑ Upward with obstructing raincap
Indicate the stack opening and size: (check one)
❑ Circular Interior stack diameter (inches):
❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑ Other (describe):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
COLORADO
3 1 L:1-' ot.h,.t
Department iEr.nrsnn.,
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
LI Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency: ! pQ
VRU Downtime or Bypassed (emissions j: 63
Qni # ecb
❑ Combustion
Device:
Pollutants Controlled: VOC & HAPs
Rating: MMBtu/hr
12 x Cimarron 48"; 1 x Cimarron 60"
Type: Enclosed Combustor 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:
)SBo
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&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 26.1 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
COLORADO
4 i n H IT S E r�mRn t
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)
V0C
Endosed Combustor & Tank VRU
96.81%
NOx
CO
HAPs
Enclosed Combustor & Tank VRU
96.81
Other:
From what year is the following reported actual annual emissions data? Projected
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factory
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg. etc) )
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
Uncontrolled
Emissions
(Tons/year)
Controlled
Emissions
(Tons/year)
VOC
4.4681 ✓
lb/bbl
ProMax
2,235.60
71.43
2,235.60
71.43 ✓
NOx
0.1380
lb/MMBtu
TCEQ
N/A
9.06
N/A
9.06 1
CO
0.2755
lb/MMBtu
TCEQ
N/A
18.09
N/A
18.09 J
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical
Emission Factory
Actual Annual Emissions
Chemical Name
Abstract
(CAS)
Service CAS
Uncontrolled
Basis
Units
Source
(AP -42,
Uncontrolled
Emissions
Controlled
Emissions8
Number
Mfg. etc)
(Pounds/year)
(Pounds/year)
Benzene
71432
0.0098 ✓
lb/bbl
ProMax
9,791.62 /
312.84 V
Toluene
108883
0.0130 ✓
lb/bbl
ProMax
13,034.70 1
416.46 ✓
Ethylbenzene
100414
0.0004 ✓
lb/bbl
ProMax
394.99 1
12.62 /
Xylene
1330207
0.0047 ✓
lb/bbl
ProMax
4,699.65 ✓
150.15 /
n -Hexane
110543
0.0849 ✓
lb/bbl
ProMax
84,931.80 1
2,713.57 ✓
Trimethylpentane
540841
0.0003'
lb/bbl
ProMax
294.96 ✓
9.42
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
y 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
COLORADO
5 EZIkV
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.
c7; ' (3
Signp'ture of Legally Authorized Person (not a vendor or consultant)
i/2, /i)(9'
/ Date
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 $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
VI COLORADO
6 HmE L�.
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
PDC Energy, Inc.
Source Name:
Barr 11 Sec HZ
Emissions Source AIRS ID2:
12aj /ft t15/ Cal
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 45689
Barr 11L-321
@
05 - 123 - 45685
Barr 11L-341
/1
05 - 123 - 45688
Barr 11L-401
4
05 - 123 - 45691
Barr 1N
/4
05-123-45690
Barr 2N
.1
05 - 123 - 45684
Barr 3N
►1
05 - 123 - 45686
Barr 4N
//
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
' 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
6/24/2019 State.co.us Executive Branch Mail - RE: [EXTERNAL] :Barr and Clark Permit Review
Hi James,
Thank you for the updated redline APEN as well as re -sending the draft permits! Please see below for PDC's comments
on the draft permits. Because claiming tank VRU in condensate tank permits is fairly new to PDC, we're still working
through establishing 'common' permit language. I recently worked through the condensate tank permit language
for PDC's Sandin Facility (Draft Permit 18WE1191) with Harrison Slaughter and most of the comments below regarding
tank VRU conditions mirror the language we came up with in that permit. PDC's preference would be to have similar
compliance requirements for similar sources if the Division finds that agreeable.
Draft Permit 19WE0104 - Barr Condensate Tanks
Equipment Description Table (page 1): Emissions Control Description - Can the control description be changed to read
"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 63.9% annual downtime."?
Condition 1: Requirement to Submit a Notice of Startup (NOS) - A hard copy NOS form was submitted with the original
application package. An electronic NOS has also been submitted to associate the AIRS ID and permit number assigned
to the condensate tanks since the original submittal. Please see the attached e -NOS receipt. Can this requirement be
removed from the permit?
Condition 8: Emissions Control Table - Can the two rows of this table be combined into a single row with the Control
Device described as "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
63.9% annual downtime."?
Condition 9: Process Limits Table - Can the process parameters be changed to "Total Condensate Throughput" (with an
Annual Limit of 1,000,700 barrels) and "Condensate Throughput During VRU Downtime" (with an Annual Limit of 639,447
barrels)?
Conditions 10 & 11: Relating to VRU Downtime Monitoring/Recording and Emissions Calculations for Demonstrating
Compliance - Can these two requirements be combined into a single requirement that reads "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."?
Notes to Permit Holder #5: Emission Factors and Calculation Methodology.- Can the note below the table be changed to
read "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. 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 /b/bbl using a GOR of 45.33 scf/bbl and a heat content of 2580 Btu/scf. Actual NOx and
CO emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput
during VRU downtime."?
Draft Permit 19WE0186 - Clark/J Clark Condensate Tanks
Condition 1: Requirement to Submit a Notice of Startup (NOS) - Because this is an existing source that required re -
permitting due to a modification, can this requirement be removed from the permit?
Condition 17: Method 22 Initial Testing Requirements - Similar to the comment above, because this is an existing source,
and one that has been subject to the monitoring requirements of CO Regulation No. 7 (specifically the
6/24/2019 State.co.us Executive Branch Mail - RE: [EXTERNAL] :Barr and Clark Permit Review
requirements regarding tank combustion devices operating without visible emissions), can this requirement be removed
from the permit?
Please let me know what your thoughts on the above comments are or if you would like to discuss any further. Also, I
have attached an updated O&M plan for the Barr condensate tanks that is more aligned with the changes mentioned
above. Please also let me know if you find this acceptable.
Finally, as I was going through all of this I realized there are two condensate tank APEN redlines that may make sense.
Would you agree that redlining Section 6 to: a) show a VRU Control Efficiency of 100% and VRU Downtime of 63.9%
(these values maintain the total CE of 96.81%) and b) show the Combustion Device Waste Gas Heat Content of 2,580
Btu/scf would better reflect the permit as drafted? Please let me know your thoughts.
Thanks again,
Jack
Jack Starr
Air Quality Representative - Wattenberg
(303) 318-61611 Direct
(720) 501-86111 Cell
Jack.Starr@pdce.com
ey PDC
PDC Energy 1 1775 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 speak to the sender of this communication. Also, please notify immediately via e-mail
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APlease consider the environment before printing this e-mail. Thank You.
From: Ricci - CDPHE, James [mailto:james.ricci@state.co.us]
Sent: Monday, June 17, 2019 1:14 PM
To: Jack Starr <Jack.Starr@pdce.com>
Subject: Re: [EXTERNAL] :Barr and Clark Permit Review
Hello