HomeMy WebLinkAbout20193770.tiffCOLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
July 24, 2019
Dear Sir or Madam:
RECEIVED
JUL 3 0 2019
WELD COUNTY
COMMISSIONERS
On July 25, 2019, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Geib 26 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
Jared Polis, Governor I Jill Hunsaker Ryan, MPH, Executive Director
Pok t c Review
og/aco(1`I
cc. • PLCTP), €H(3T), OC,Ca01
PW ( zmI ERICH/Ck)
3/19/I 9
2019-3770
a
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Geib 26 Sec HZ - Weld County
Notice Period Begins: July 25, 2019
Notice is hereby given that an application for a proposed projector activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: PDC Energy, Inc.
Facility: Geib 26 Sec HZ
Exploration Ft Production Well Pad
NENE Sec 26 T5N R65W
Weld County
The proposed project or activity is as follows: This is a new facility that began operation with it's nine
newly drilled wells 1 /28/2019. The facility consists of 18 -liquid manifolded condensate storage tanks (as
requested in this permit application), condensate loadout (GP07 permit coverage), and six natural gas
engines (GP02 permit coverage). The source is synthetic minor for NOx, VOC, and CO. This source is subject
to COGCC 805.b.(2)A.
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 19WE0528 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:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
g (COLORADO
1 DeprtmentofPublic
& Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
COLORADO
Mr Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number:
Date issued:
Issued to:
19WE0528
Facility Name:
Plant AIRS ID:
Physical Location:
County:
Description:
Issuance: 1
PDC Energy, Inc.
Geib 26 Sec HZ
123/A04A
NENE SEC 26 T5N R65W
Weld County
Well Production Facility
Equipment or activity subjectto this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TK-1
001
Eighteen (18) 538 barrel fixed roof storage
vessels used to store condensate
Enclosed Combustion
Device
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
Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may result
in revocation of the permit. A self certification form and guidance on how to self -certify
compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air-
permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was issued:
(i) does not commence construction/modification or operation of this source within 18 months
after either, the date of issuance of this construction permit or the date on which such
construction or activity was scheduled to commence as set forth in the permit application
associated with this permit; (ii) discontinues construction for a period of eighteen months or
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.)
Page 1 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
3. The operator must complete all initial compliance testing and sampling as required in this
permit and submit the results to the Division as part of the self -certification process.
(Regulation Number 3, Part B, Section III.E.)
4 The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants must 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,t
VOC
CO
TK-1
001
---
3.2
30.0
6.3
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility -wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility -wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air pollutants, must be
determined on a rolling twelve (12) month total. By the end of each month a new twelve month
total is calculated based on the previous twelve months' data. The permit holder must calculate
actual emissions each month and keep a compliance record on site or at a local field office with
s'te 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 must be operated and maintained with the emissions
control equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit. (Regulation Number 3, Part B, Section III.E.)
Facility
Equipment
ID
AIRS
Point
Control Device
Pollutants
Controlled
TK-1
001
Enclosed Combustion Device
VOC and HAP
Page 2 of 9
a
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
PROCESS LIMITATIONS AND RECORDS
8. This source must be limited to the following maximum processing rates as listed below. Monthly
records of the actual processing rates must be maintained by the owner or operator and made
available to the Division for inspection upon request. (Regulation Number 3, Part B, II.A.4.)
Process Limits
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
TK-1
001
Condensate
throughput
1,469,340 barrels
The owner or operator must monitor monthly process rates based on the calendar month.
Compliance with the annual throughput limits must be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on the
previous twelve months' data. The permit holder must calculate throughput each month and
keep a compliance record on site or at a local field office with site responsibility, for Division
review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. The permit number and__ ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001)
must be marked on the subject equipment for ease of identification. (Regulation Number 3,
Part B, Section III.E.) (State only enforceable)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. This source is subject to Regulation Number 7, Section XII. The operator must comply with all
applicable requirements of Section XII and, specifically, must:
• 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)
12. 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 must be
enclosed; have no visible emissions during normal operations, as defined under Regulation
Number 7, XVII.A.17; 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;
Page 3 of 9
a
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
13. 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 must install and operate air
pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If
a combustion device is used, it must have a design destruction efficiency of at least 98% for
hydrocarbons except where the combustion device has been authorized by permit prior to May
1, 2014. The source must 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.
14. 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
15. Upon startup of these points, the owner or operator must 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 withthe requirements of this permit. Revisions to
the O&M plan are subject to Division approval prior t o implementation. (Regulation Number 3,
Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator must demonstrate compliance with!', opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen -minute period during normal
operation. (Regulation Number 7, Sections XII.C, XVII.B.2. and XVII.A.17)
Periodic Testing Requirements
17. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
Page 4 of 9
a
COLORADO
Air Pollution Control Division
Department of. Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
For volatile organic compounds (VOC) and nitrogen oxides sources (NO,) in ozone
nonattainment areas emitting less than 100 tons of VOC or NO,t per year, a change in
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.
19. Federal regulatory program requirements ((.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
20. This permit and any attachmentsmust 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.
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
Page 5 of 9
a. �NxwrM
COLORADO
Mr Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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 must constitute a rejection of the entire permit
and upon such occurrence, this permit must be deemed denied ab initio. This permit may be
revoked at any time prior to self -certification and final authorization by the Air Pollution
Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and
regulations of the Air Quality Control Commission (AQCC), including failure to meet any express
term or condition of the permit. If the Division denies a permit, conditions imposed upon a
permit are contested by the owner or operator, or the Division revokes a permit, the owner or
operator of a source may request a hearing before the AQCC for review of the Division's action.
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.
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
Page 6 of 9
a
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
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit.
(Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written
notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-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 listedto 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)
Benzene
71432
3,268
163
001
Toluene
108883
4,470
224
Ethylbenzene
100414
112
6
Xylenes
1330207
1,658
83
n -Hexane
110543
30,513
1,526
2,2,4-
Trimethylpentane
540841
65
3
Note: All non -criteria reportable pot utants 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 7 of 9
a
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
4.30E-03
4.30E-03
TCEQ Flare
Emissions
Guidance
CO
8.59E-03
8.59E-03
VOC
0.8155
0.04078
ProMax
Simulation based
on Site Specific
LPressurized
Analysis Sample
taken
4/8/2019
71432
Benzene
0.0022
1.1E-04
108883
Toluene
0.0030
1.5E-04
100414
Ethylbenzene
0.0001
5.0E-06
1330207
Xylene
0.0011
5.5E-05
110543
n -Hexane
0.0208
1.04E-03
540841
2,2,4-
Trimethylpentane
4.45E-05
2.23E-06
Note: The controlled emissions factors for this point are based on a control efficiency of 95%.
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated
control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when
applicable.
8) This source is subject to 40 CFR, Part 60, Subpart 0000a - Standards of Performance for Crude Oil
and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced
after September 18, 2015 (See June 3, 2016 Federal Register posting - effective August 2,
2016.) This rule has not yet been incorporated into Colorado Air Quality Control Commission's
Regulation No. 6. A copy of the complete subpart is available at the Office of the Federal Register
website at: https://www.federalregister.gov/documents/2016/06/03/2016-11971 /oil-and-
natu rat -Ras -sector -emission -standards-for- new- reconstructed -and - modified -sources
9) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, NOx
PSD
True Minor Source
NANSR
Synthetic Minor Source of: VOC, NOx
10) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
Page 8 of 9
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
http: //www.ecfr.Rov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source
Categories
MACT
63.1-63.599
Subpart A - Subpart Z
MACT
63.600-63.1199
Subpart AA - Subpart DDD
MACT
63.1200-63.1439
Subpart EEE - Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ - Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN - Subpart XXXXXX
Page 9 of 9
Colorado Air Permitting Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Lauraleigh Lakocy
Package #: 400313
Received Date: 4/30/2019
Review Start Date: 6/25/2019
Section 01 - Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Quadrant
Section
Township
Range
NENE
' :
°,*;
Plant AIRS ID:
Facility Name:
Physical
Address/Location:
County:
Type of Facility:
A04A
Gelb 26 Sec HZ
NENE quadrant of Section 26, Township 5N, Range 65W
Weld County
Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility ocated in a NAAQS non -attainment area?
If yes, for what pollutant? I I Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
Yes
Particulate Matter (PM)
Ozone (NOx & VOC)
AIRs ['Dint #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering
Remarks
Condensate Tank
.:
19WE0528
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
This is a new facility that began operation with it's nine newly drilled wells 1/28/2019. The facility consists of 18 -liquid manifolded condensate storage tanks (as requested in
this permit application), condensate loadout (GPO?' permit coverage), and six natural gas engines (GP02 permit coverage). The source is synthetic minor for NOx, VOC, and CO.
This source is subject to COGCC 805.b.(2)A. Source has submitted a NOS, so there will not be an initial condition requiring the re -submission of an NOS.
Section 04 - Public Comment Requirements
Is Public Comment Required?
If yes, why? Requesting Synthetic Minor Permit
Section 05 - ambient Air Impact Analysis Requirement
Yes
Was a quantitative modeling analysis required?
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06 - Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
Is this stationary source a synthetic minor?
If yes, indicate programs and which pollutants:
Prevention of Significant Deterioration (PSD)
Title V Ope-ating Permits (OP)
Non -Attainment New Source Review (NANSR)
SO2 NOx
Is this statiorary source a major source?
If yes, explain what programs and which pollutants herE SO2
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP)
Non -Attainment New Source Review (NANSR)
J
CO '✓OC PM2.5 PM10 TSP HAPs
Nc.
NOx CO
VOC
i _
PM2.5 PM10 TSP HAPs
Condensate Storage Tank(s) Emissions Inventory
001 Condensate Tank
Facility AIRs ID:
123 AO4A
County Plant
001
Point
Section 02 - Equipment Description Details
Detailed Emissi ins Unit
Description:
Eighteen (18) 538 bbl storage tanks for condensate liquids (tOtaf volume: 9,,684 bbls)
Emission Control Device Enclosed Combustion Devices (9xCimaron 48", 1 x Big Iron 60")
Description:
Requested Overall VOC & HAP Control
Efficiency %: r- ;
Section 03 - Prccessing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
1,224,454 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
1,224,454 Barrels (bbl) per year
Requested Permit Limit Throughput =
1,469,340 Barrels (bbl) per year Requested Monthly Throughput =
121/93 Barrels (bbl) per month
Potential to Em t (PTE) Condensate Throughput
1,469,340 Barrels (bbl) per year
Secondary Emissions - Combustion Device(s)
Heat content of waste gas= 231635 Btu/scf
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat consent of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
10.07365409 scf/bbl
38,167 MMBTU per year
45,800 MMBTU per year
Potential to Emit (PTE) heat content of waste gas routed to combustion device = 45,800 MMBTU per year
Section 04 - Em ssions Factors & Methodologies
Will this storage tank emit flash emissions?
Emission Factors
Condensate Tank
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
Emission Factor Source
(Condensate
Throughput)
(Condensate
Throughput)
VOC
0,82
0.04
• to Specific i; F., (includes fat
Benzene
0.002
0.000
Site Specific. ES, (includes ffa 4t)
Toluene
0.003
0.000
Sitsi7SpecificES.(includesfl.;
Ethylbenzene
0.000
0.000
Site Specific E.F. (includes fia 't'
$ to Specie E.F. (includesfla :=
Site Specific E.F.. (includes flash)
Site p fsc «E One) :14. an 9,
Xylene
0.001
0.000
n -Hexane
0.021
0.001
224 TMP
0.000
0.000
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (lb/bbl)
(waste heat
combusted)
(Condensate
Throughput)
PM 10
0.0002
PM2.5
0.0075
0.0002
mgt.
NOx
0.1380
0.0043
CO
0.2755
0.0086
Section 05 - Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrclled Controlled
(tons/year) (tons/year)
Requested Monthly Limits
Controlled
(lbs/month)
VOC
PM10
PM2.5
NOx
599.2
499.3
25.0
599.2
30.0
5089
0.2
0.1
0.1
0.2
0.2
29
0.2
0.1
0.1
0.2
0.2
29
3.2
2.6
2.6
3.2
3.2
537
CO
6.3
5.3
5.3
6.3
6.3
1072
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
3268
2724
136
3268
163
Toluere
4470
3725
186
4470
224
Ethylbenzene
112
94
5
112
6
Xylene
1658
1382
69
1658
83
n -Hexane
30513
25428
1271
30513
1526
224 IMP
65
54
3
65
3
Section 06 - Regilatory Summary Analysis
Regulation 3, Pals 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)
2 of 7
K:\PA\2019\19WE0528.CP1
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 equa' to 80 tons VOC per year?
If yes, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company use a site specific emissions factor to estimate emissions?
If yes and if there are flash emissions, are the emissions factors based on a pressurized liquid sample drawn at the
facility being permitted? 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
Waste Gas Heat Content is combination of the contributions from flash gas and working/breathing emissions stream.
The ProMax simulation is based on a site -specific pressurized liquid sample taken 4/8/2019.
Source requested combustion emissions are greater than those reflected above, as the source used a different calculation methodology, which did not include the scf/bbi value from ProMax. Their
calculation methodlogy is outlined below and will be reflected in the permit limits:
Flash Gas (MMBtu/yr) = Uncontrolled VOC (ton/yr)*(20001b/ton)*(1/Gas MW)*(379.41 SCF Gas/Ib-mol)*(1/VOC%)*Heat Content (BTU/SCF)*(1 MMBTU/10^6 BTU)
NOx & CO (ton/yr) = Emission factor (Ib/MMBTU) * Flash Gas (MMBTU/yr)*(1 ton/20001b)
Gas MW (From ProMax Simulation) = 43.1266 (average of flash/w/b)
VOC% (From ProMax Simulation) = 54.978%
This source is subject to NSPS OOOa. Because each vessel emits less than 6 tpy VOC, the tanks are not subject to the requirements for a storage vessel affected facility requirements. Because the wells
were fractured after September 2015, this is a well affected facility.
Section 09 - Inventory SCC Coding and Emissions Factors
AIRS Po nt #
001
Process #
01
SCC Code
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.01 0 lb/1,000 gallons condensate throughput
PM2.5 0.01 0 lb/1,000 gallons condensate throughput
NOx 0.10 0 Ib/1,000 gallons condensate throughput
VOC 19.4 95 lb/1,000 gallons condensate throughput
CO 0.20 0 lb/1,000 gallons condensate throughput
Benzene 0.05 95 Ib/1,000 gallons condensate throughput
Toluene 0.07 95 lb/1,000 gallons condensate throughput
Ethylbenzene 0.00 95 lb/1,000 gallons condensate throughput
Xylene 0.03 95 lb/1,000 gallons condensate throughput
n -Hexane 0.49 95 lb/1,000 gallons condensate throughput
224 TMP 0.00 95 lb/1,000 gallons condensate throughput
3 of 7 K:\PA\2019\19WE0528.CP1
Condensate Tank Regulatory Analysis Worksheet
Colorado Re ulation 3 Parts A and B - APEN and Permit Re uirements
Source is in the Non -Attainment Area
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (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 S 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
�H%i/Jd197
rvio iu i, uii
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 P5 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 2 TPY, NOx greater than 5 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
Yes
Yes
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 uncontro led actual emissions greater than or equal to 2 tons per year VOC?
Storage Tank is not subject to Rega ation 7, Section XII.G
Yes
Yes
No
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' or 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?
Storage tank is subject to Regulations 7. Section XVII. B. C.1 & C.3
Yes
Yes.
Yes
Section XVII.B — General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVIl.C.1 - Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5 Does the condensate storage tank contain only "stabilized" liquids?
Storage tank is subject to Regulation 7, Section XVII.C.2
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 (m3) (`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 m3 [`10,000 BBL] used for petroleum' or condensate stored, processed, or treated prior to custody transfers as defined in 6O.111b?
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"3 in 60.111b?
5. Does the storage vessel store a "volatile organic liquid (VOL)"s 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 m3 h950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 35 kPa (60.110b(b))?; or
c. The design capacity is greater than or equal to 75 M3 [`472 BBL] but less than 151 m3 ("-950 BBL] and stores a liquid with a maximum true vapor pressure6 less than 15.0 kPa(60.110b(b))?
Source Req
Go to next
Source Req
Continue -'
Continue -'
Source is st
Continue -'
Storage Tar
Source is st
Continue -'
Go to the n
Go to then
Source is st
Source is st
Go to the n
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 60, 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 yea'?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
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 H H?
Storage Tank is not subject to NSPS OOOO
Subpart A, General Provisions per §60.5425 Table 3
§60.5395 - Emissions Control Standards for VOC
§60.5413 - Testing and Procedures
§6O.5395(g) - Notification, Reporting and Recordkeeping Requirements
§60.5416(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 OOOO due to emissions above 6 tons per year VOC on the applicability determination date, it should remain subject to NSPS OOOO per 60.5365(e)(2) even
if potential VOC emissions drop below 6 tons per year)
4C CFR, Part 63, Subpart MACT NH, 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 liquids2 (63.760(a)(2)); OR
b. A facility that processes, upgrades or stores natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user3 (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"5 per 63.761?
5. Is the tank subject to control requirements under 40 CFR Part 60, Subpart Kb or Subpart 0000?
Storage Tank is not subject to MACT HH
Subpart A, General provisions per §63.764 (a) Table 2
§63.766 - Emissions Control Standards
§63.773 - Monitoring
§63.774 - Recordkeeping
§63.775 - Reporting
Yes
No
NA
N
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 RAG requirements.
Disclaimer
This document assists operators with determining applicability of certain requirements of the Clean Air Act, its implementing regulations. and Air Quality Control Commission regulations. This document is
not a rule or regulation, 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 sta:ute 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 to describe controlling requirements under the terms of the Clean Air Act
and Air Quality Control Commission regulations. but this document does not establis'1 legally binding requirements in and of itself
N
Continue - -
Storage Tar
Continue -'
Storage Tar
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
A04A
Facility Name
Geib 26 Sec HZ
History File Edit Date
7/5/2019
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year
EMISSIONS With Controls (peyea
tons r r
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
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
19WE0528
Condensate Tanks (18)-
3.2
599.2
6.3
0.0
3.2
30.0
6.3
0.0
Newly Requested
Source
002
GP07
Condensate Loadout
0.9
173.4
1.8
2.9
0.9
10.0
1.8
0.1
State
EF's,
Nox/CO from TCEQ
003
GP02
Cummins 4SRB 188 HP NG
0.1
0.1
10.2
3.3
46.0
0.2
0.1
0.1
1.7
1.2
3.4
0.2
Newly Requested
Source
004
GP02
Cat.
G3306NA 4SRB 145
HP
0.1
0.1
17.9
0.9
17.9
0.4
0.1
0.1
1.3
0.9
2.7
0.4
Newly Requested
Source
005
GP02
Cat. G3306NA 4SRB
145 HP
0.1
0.1
17.9
0.9
17.9
0.4
0.1
0.1
1.3
0.9
2.7
0.4
Newly Requested
Source
006
GP02
Cat. G3306NA 4SRB
145 HP
0.1
0.1
17.9
0.9
17.9
0.4
0.1
0.1
1.3
0.9
2.7
0.4
Newly Requested
Source
007
GP02
Cat. G3306NA 4SRB
145 HP
0.1
0.1
17.9
0.9
17.9
0.4
0.1
0.1
1.3
0.9
2.7
0.4
Newly Requested
Source
008
GP02
Cat. G3406TA
4SRB
276 HP
0.2
0.2
41.1
1.9
41.1
0.8
0.2
0.2
2.7
1.9
5.3
0.8
Newly Requested
Source
0.0
0.0
0.0
0.0
APEN
Exempt/Insignificant
Sources
0.0
0.0
Per Form APCD-102, Received 4/30/19
External Combustion Source
0.2
0.2
2.2
1.8
0.0
0.2
0.2
2.2
1.8
0.0
9 Burners - Grouped
for Visibility Only
Fugitives
0.3
0.0
0.3
0.0
Produced Water Tanks
0.6
0.1
0.6
0.1
2.8
FACILITY TOTAL
0.9
0.9
0.0
0.0
129.2
782.0
0.3
168.6
5.8
0.9
0.9
0.0
0.0
15.9
47.3
0.3
29.4
5.8
VOC: Syn Minor
NOx: Syn Minor
CO: Syn Minor (OP),
HAPS: True Minor
(NANSR
(NANSR
and OP)
and OP)
True Minor
(PSD)
Permitted Facility Total
0.7
0.7
0.0
0.0
127.0
781.4
0.0
166.8
5.6
0.71
0.7
0.0
0.0
13.71
46.71
0.01
27.6
2.8
Excludes units exempt from
(IL) Change
in Permitted
Emissions
0.7
0.7
0.0
0.0
13.7
46.7
0.0
27.6
Pubcorn required because requesting
minor limits. Modeling not required
on division guidelines.
syn
based
Total VOC Faci
ity Emissions (point
and
fugitive
47.6
Facility is eligible for GP02 because < 90
;A) Change in Total Permitted VOC emissions (point
and fugitive
46.7
_
Project
emissions not less than 25 tpy*
Note
1
Source will be required
to go through the
public comment
process as the
project emissions are greater than 25 tpy.
Note
2
Page 5 of 7
Printed 7/19/2019
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
A04A
Geib 26 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)
!Previous
FACILITY
TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
19WE0528
Condensate
Tanks
(18)-9,684bb1
0.0
002
G P07
Condensate
Loadout
602
5290
2.9
003
GP02
Cummins 4SRB
188
HP
NG
RICE
276
38
35
21
41
0.2
004
GP02
Cat.
G3306NA
4SRB
145
HP
719
29
27
16
32
0.4
s.
005
GP02
Cat.
G3306NA
4SRB
145
HP
719
29
27
16
32
0.4
006
GP02
Cat.
G3306NA
4SRB
145
HP
719
29
27
16
32
0.4
007
GP02
Cat.
G3306NA
4SRB
145
HP
719
29
27
16
32
0.4
008
GP02
Cat.
G3406TA
4SRB
276
HP
1440
50
47
28
55
0.8
0.0
0.0
APEN
Exempt/Insignificant
Sources
0.0
External
Combustion
Source
0.0
Fugitives
10
11
10
10
-.
0.0
Produced
Water
Tanks
88
114
29
10
0.1
TOTAL
(tpy)
2.3
0.1
0.1
0.4
0.0
0.0
0.0
2.6
0.1
0.0
0.0
0.0
5.6
1
*Total
Reportable
= all
HAPs
where
uncontrolled
emissions > de
minimus values
Red Text: uncontrolled emissions < de minimus
Emissions with
controls
(lbs
per year)
POIN
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
224 TMP
TOTAL
(tpY)
Ethylbenzene
Xylenes
n -Hexane
McOH
H2S
(Previous
FACILITY
TOTAL
0
0
0
0
0
0
0
0
0.0
0
0
0
0
001
19WE0528
Condensate
Tanks
(18)-9,684bbI
0.0
002
G
P07
Condensate
Loadout
30
264
0.1
003
GP02
Cummins 4SRB
188
HP
NG
RICE
276
38
35
21
0.2
4 i
004
GP02
Cat.
G3306NA
4SRB
145
HP
p 719
29
27
16
0.4
32
005
GP02
Cat. G3306NA
4SRB 145
HP
719
29
27
16
0.4
32
006
GP02
_Cat.
G3306NA
4SRB
145
HP
_
719
29 _
:. / _
16
0.4
32
6
19WE0528.CP1
7/19/2019
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
A04A
Geib 26 Sec HZ
007
GP02
Cat.
G3306NA
4SRB
145
HP
719
29
16
32
0.4
008
GP02
Cat. G3406TA
4SRB
276
HP
1440
50
28
55
0.8
0.0
1
0.0
APEN
Exempt/Insignificant
Sources
0.0
External
Combustion
Source
0.0
Fugitives
'
y
11
0.0
Produced
Water
Tanks
114
0.1
TOTAL
(tpy)
2.3
0.1
0.1
0.1
i
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.0
2.8
1
7
19WE0528.CP1 7/19/2019
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:
t' l WEQI sAIRS ID Number: 12-3 '�TA /1® I
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 1 - Administrative Information
Company Name': PDC Energy, Inc.
Site Name: Geib 26 Sec HZ
Site Location: NENE Sec 26 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 AVICOLORAOO
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
❑ 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 O Other (describe below)
-OR-
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et 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:
Company equipment Identification No. (optional):
Condensate Storage Tanks
TK-1
For existing sources, operation began on: 01/28/2019
For new or reconstructed sources, the projected start-up date is:
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week
❑✓ Exploration a Production (EEtP) site
52
weeks/year
O Midstream or Downstream (non MP) site
Will this equipment be operated in any NAAQS nonattainment area?
4
Yes
•
No
Are Flash Emissions anticipated from these storage tanks?
NI
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:
0.001794
m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC)12
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
■
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
COLORADO
2 I o
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit # and AIRS ID]
Section 4 - Storage Tank(s) Information
Condensate Throughput:
Actual Annual Amount
(bbl/year)
1,224,454
From what year is the actual annual amount?
Projected
Average API gravity of sales oil: 51.8 degrees
Tank design: El Fixed roof ❑ Internal floating roof
Requested Annual Permit Limits
(bbl/year)
1,469,340
RVP of sales oil: 7.9
❑ 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
18
9,684
3/2018
1/2019
Wells Serviced by this Storage Tank or Tank Battery(' (EEtP Sites Only)
API Number
Name, of Well
Newly Reported Well
05
123
44855
Geib 26U-234
FA
05
123
44863
Geib 26U-304al
05
123
44858
Geib 26V-214El
05
- 123
- 44861
Geib 26V 234
0
05
- 123
- 44856
Geib 26V 304
0
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The EaP 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)
40.3743 / -104.62245
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)
❑ Circular
O Square/rectangle
❑ Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches):
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 7/2018
AV
COLOR 4DO
3 I mV I otR�
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:
Vapor
❑ Recovery
Unit (VRU):
Size: Make/Model:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
‘"Combustion
Device:
Pollutants Controlled: VOC & HAPs
Rating: MMBtu/hr
9 x Cimarron 48", 1 x Big Iron 60"
Type: Enclosed Combustors Make/Model:
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature:
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating:
Waste Gas Heat Content: 2,357.66 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 (EaP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 21.8 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 AV' ��;
Farithc Enuieonmarv�
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
control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combustor
95%
NOx
CO
HAPs
Enclosed Combustor
95%
Other:
From what year is the following reported actual annual emissions data? Projected
Pollutant
VOC
Criteria Pollutant Emissions Inventory
Emission Factor7
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
0.8155
lb/bbl
Source
(AP -42,
Mfg. etc)
ProMax
Uncontrolled
Emissions
(Tons/year)
499.30
Controlled
Emissions8
(Tons/year)
24.97
Uncontrolled
Emissions
(Tons/year)
599.16
Controlled
Emissions
(Tons/year)
29.96
NOx
0.1380
Ib/MMBtu
TCEQ
N/A
2.63
N/A
3.16
CO
0.2755
lb/MMBtu
TCEQ
N/A
5.26
N/A
6.31
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
Emissions 8
(Pounds/year)
Benzene
71432
0.0022
lb/bbl
ProMax
2,723.60
136.18
Toluene
108883
0.0030
lb/bbl
ProMax
3,725.07
186.25
Ethylbenzene
100414
0.0001
lb/bbl
ProMax
93.57 (DM)
4.68 (DM)
Xylene
1330207
0.0011
lb/bbl
ProMax
1,381.52
69.08
n -Hexane
110543
0.0208
lb/bbl
ProMax
25,427.3
1,271.37
2,2,4-
Trimethylpentane
540841
4.45E-05
lb/bbl
ProMax
54.44 (DM)
2.72 (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
®��COLORADO
5 .:..1° E°;.1 of
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 alt 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 GP0B, I further certify that
this source is and will be operated in full compliance with each condition of the applicable General Permit.
Signre of Legally Authorized Person (not a vendor or consultant)
Jack Starr
Z.4' ZQ
Date I
Air Quality Representative
Name (print) Title
Check the appropriate box to request a copy of the:
✓Q 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-B1
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 A
COLOR ADO
uera rn�L
IieaNltk Em+l.nnmanl
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Forml
Company Name:
PDC Energy, Inc.
Source Name:
Geib 26 Sec HZ
Emissions Source AIRS ID2:
/ /
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 44860
Geib 26V-314
Fa
05 - 123 - 44862
Geib 26V-334
0
05 - 123 - 44859
Geib 26W-214
05 -123 - 44857
Geib 26W-304
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
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 APEN Addendum
Hello