HomeMy WebLinkAbout20200622.tiffCOLORADO
Department of Public
Health b Environment
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
September 30, 2020
Dear Sir or Madam:
RECEIVED
OCT 0 2 2020
WELD COUNTY
COMMISSIONERS
On October 1, 2020, the Air Pollution Control Division will begin a 30 -day public notice period for
PDC Energy, Inc. - McNear 10-9 Pad. A copy of this public notice and the public comment packet are
enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polls, Governor I Jill Hunsaker Ryan, MPH, Executive Director
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CDPHE
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - McNear 10-9 Pad - Weld County
Notice Period Begins: October 1, 2020
Notice is hereby given that an application for a proposed project or activity has been submitted to the
Colorado Air Pollution Control Division for the following source of air pollution:
Applicant: PDC Energy, Inc.
Facility: McNear 10-9 Pad
Exploration Et Production Well Pad Facility.
NWSE SEC 9 T6N R66W
Weld County
The proposed project or activity is as follows: Applicant proposes permitting of one condensate tank
battery and one loadout operation at an OEtG production facility which was newly constructed in the NAA in
Weld County in August, 2019.
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 19WE0810 have been
filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are
available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices
The Division hereby solicits submission of public comment from any interested person concerning the ability
of the proposed project or activity to comply with the applicable standards and regulations of the
Commission. The Division will receive and consider written public comments for thirty calendar days after
the date of this Notice. Comments may be submitted using the following options:
• Use the web form at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices. This page
also includes guidance for public participation
• Send an email to cdphe.commentsapcd@state.co.us
• Send comments to our mailing address:
Ben Fischbach
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
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COLORADO
Department of Public
Health Et Environment
COLORADO
Air Pollution Control Division
I Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0810 Issuance: 1
Date issued:
Issued to: PDC Energy, Inc.
Facility Name: McNear 10-9 Pad
Plant AIRS ID: 123/A07B
Physical Location: NWSE SEC 9 T6N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility
Equipment
ID
AIRS
Point
Equipment Description
Emissions Control
Description
TNK 1-6
001
Six (6) 400 barrel fixed roof storage vessels
used to store condensate
Enclosed Flare
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self -certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self -
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
Page 1 of 14
COLORADO
Air Pollution Control Division
Department of Public Health 6 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.)
I. F.4. )
3. Upon issuance of this permit, the operator must install equipment necessary to monitor
control device pilot light status and auto -igniter status as described in this permit.
4. 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.)
5. 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
6. 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
NOX
VOC
CO
TNK 1-6
001
---
2.1
23.9
9.8
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 alt 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 site responsibility for Division review.
7. The owner or operator must use the emission factors and calculation methods 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.
8. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility potential emission limitations as
indicated below. An inventory of each insignificant activity and associated emission
calculations must be made available to the Division for inspection upon request. For the
purposes of this condition, insignificant activities are defined as any activity or equipment,
Page 2 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
which emits any amount but does not require an Air Pollution Emission Notice (APEN) or is
permit exempt. (Regulation 3, Part C. II.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC
9. 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
TNK 1-6
001
Emissions are routed to a bank of four (4)
Enclosed Flares.
Make: IES, Model: 96", SNs: 96-01-118, 96-
01-119, 96-01-120, 96-03-0130
VOC and HAP
PROCESS LIMITATIONS AND RECORDS
10. 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
TNK 1-6
001
Condensate throughput
1,180,848 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.
11. On a minimum of an hourly basis, the owner or operator shall monitor the control devices for
the presence of a pilot light and an operational auto -igniter on each device. These
monitoring records shall be used to calculate control device downtime. During periods
without the presence of a pilot light and/or an operational auto -igniter, the flow volume from
emissions source(s) shall be assigned a 0% control efficiency. These monitoring records must
be maintained for a period of five (5) years, and a summary of monthly pilot light downtime
and vapor flow during pilot light downtime shall be provided to the division upon request.
Page 3 of 14
at,
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply
with all applicable requirements of Section I and, specifically, must:
• Comply with the recordkeeping, monitoring, reporting and emission control
requirements for storage tanks; and
• Ensure that the combustion device controlling emissions from this storage tank be
enclosed, have no visible emissions, and be designed so that an observer can, by
means of visual observation from the outside of the enclosed combustion device, or by
other means approved by the Division, determine whether it is operating properly.
(Regulation Number 7, Part D, Section I.C.) (State only enforceable)
15. The combustion device covered by this permit is subject to Regulation Number 7, Part D,
Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion
device is used to control emissions of volatile organic compounds to comply with Section II, it
must be enclosed; have no visible emissions during normal operations, as defined under
Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by
means of visual observation from the outside of the enclosed flare or combustion device, or
by other convenient means approved by the Division, determine whether it is operating
properly. This flare must be equipped with an operational auto -igniter according to the
schedule in Regulation Number 7, Part D, Section II.B.2.d.
16. The storage tank covered by this permit is subject to the emission control requirements in
Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate
air pollution control equipment that achieves an average hydrocarbon control efficiency of
95%. If a combustion device is used, it must have a design destruction efficiency of at least
98% for hydrocarbons except where the combustion device has been authorized by permit
prior to March 1, 2020. The source must follow the inspection requirements of Regulation
Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of
two years, made available to the Division upon request. This control requirement must be
met within 90 days of the date that the storage tank commences operation.
17. The storage tanks covered by this permit are subject to the venting and Storage Tank
Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section
II.C.2.
18. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
Page 4 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING £t MAINTENANCE REQUIREMENTS
19. 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 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
20. The owner or operator must complete site specific sampling including a compositional analysis
of the pre -flash pressurized condensate routed to these storage tanks and, if necessary for
emission factor development, a sales oil analysis to determine RVP and API gravity. Testing
must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must
be used to determine site -specific emissions factors for VOC and Hazardous Air Pollutants
using Division approved methods. Results of site -specific sampling and analysis must be
submitted to the Division as part of the self -certification and used to demonstrate compliance
with the emissions factors chosen for this emissions point.
21. 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, Part D, Sections I.C, II.B.2. and II.A.23)
22. The owner or operator must conduct an initial source compliance test to measure the mass
emission rates of the pollutants listed below, demonstrate compliance with the VOC emissions
limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for volatile
organic compounds (VOC). During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M1) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (M0) using EPA or other
division approved methods; and
•. mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
Page 5 of 14
COLORADO
Air Pollution Control Division
�l�' �' , Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(M;-Mo)/M;
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must include testing
under all operating scenarios of the control device. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Results of the initial compliance tests must be submitted to the Division as part of the self -
certification. Actual emissions calculations must be completed in accordance with the "Notes
to Permit Holder" section of this permit. If the results of the initial compliance test do not
demonstrate compliance with the emissions limits contained within this permit or do not
demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC)
for each operating scenario, the owner or operator must submit to the Division within 60
days, or in a timeframe as agreed to by the Division, a request for permit modification to
address these inaccuracies.
Periodic Testing Requirements
23. On an annual basis, the owner or operator must complete a site specific analysis ("Analysis"),
including a compositional analysis of the pre -flash pressurized hydrocarbon liquid routed to
the equipment covered in this permit. Testing must be in accordance with the guidance
contained in PS Memo 05-01. Results of the Analysis must be used to demonstrate that the
emissions factor established through the Analysis is less than or equal to the emissions factor
submitted with the permit application and established herein in the "Notes to Permit Holder"
for this emissions point. If any site specific emissions factor developed through this Analysis is
greater than the emissions factors submitted with the permit application and established in
the "Notes to Permit Holder" the operator must submit to the Division within 60 days, or in a
timeframe as agreed to by the Division, a request for permit modification to address these
inaccuracies.
24. On an annual basis, the owner or operator must conduct a source compliance test to measure
the mass emission rates of the pollutants listed below, demonstrate compliance with the VOC
emissions limit in this permit, and to demonstrate a minimum destruction efficiency of 98% for
volatile organic compounds (VOC). During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (MO using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Page 6 of 14
COLORADO
Air Pollution Control Division
Department cf Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(M;-Mo)/M;
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must include testing
under all operating scenarios of the control device. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Actual emissions calculations must be completed in accordance with the "Notes to Permit
Holder" section of this permit. If the results of the periodic compliance test do not
demonstrate compliance with the emissions limits contained within this permit or do not
demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC)
for each operating scenario, the owner or operator must submit to the Division within 60
days, or in a timeframe as agreed to by the Division, a request for permit modification to
address these inaccuracies.
ALTERNATIVE OPERATING SCENARIOS
25. The control device may be replaced with a like -kind control device in accordance with the
requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this
permit or obtaining a new construction permit. A like -kind control device shall be the same
make and model as authorized in this permit. All control device replacements installed and
operated as authorized by this permit must comply with all terms and conditions of this
construction permit. The owner or operator shall maintain a log on -site or at a local field
office to record the start and stop dates of any control device replacement, the
manufacturer, model number and serial number of the replacement control device.
26. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and
serial number of the replacement control device must be filed with the Division within 14
calendar days of commencing operation of a replacement control device under the
Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate
APEN filing fee and a cover letter explaining that the owner or operator is exercising an
Alternative Operating Scenario and has replaced the control device.
Page 7 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
27. Within one hundred and eighty days (180) of startup of the replacement control device in
accordance with the Alternate Operating Scenario provision, the owner or operator must
conduct an initial source compliance test to measure the mass emission rates of the pollutants
listed below, demonstrate compliance with the emissions limit in this permit, and to
demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC).
During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (Mi) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (M0) using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(Mi-Mo)/M1
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must include testing
under all operating scenarios of the control device. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Actual emissions calculations must be completed in accordance with the "Notes to Permit
Holder" section of this permit. If the results of the initial compliance test do not demonstrate
compliance with the emissions limits contained within this permit or do not demonstrate a
minimum destruction efficiency of 98% for volatile organic compounds (VOC) for each
operating scenario, the owner or operator must submit to the Division within 60 days, or in a
timeframe as agreed to by the Division, a request for permit modification to address these
inaccuracies.
Page 8 of 14
ktty
COLORADO
Air Pollution Control Division
Department of Public Health fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
28. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
II.C.)
• Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of five
(5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) 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.
29. The requirements of Colorado Regulation No. 3, Part D must apply at such time that any
stationary source or modification becomes a major stationary source or major modification
solely by virtue of a relaxation in any enforceable limitation that was established after August
7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a
restriction on hours of operation (Reference: Regulation Number 3, Part D, V.A.7.B).
GENERAL TERMS AND CONDITIONS
30. 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.
31. 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
Page 9 of 14
COLORADO
Air Pollution Control Division
Department of Public Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
32. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
33. 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.
34. 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.
35. 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.
36. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Page 10 of 14
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 History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
New Synthetic Minor Facility
Page 11 of 14
COLORADO
toe Air Pollution Control Division
I Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for
these fees will be issued after the permit is issued. The permit holder must pay the invoice within
30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this
permit. (Regulation Number 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice
(APEN) and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative
Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify
the Division of any malfunction condition which causes a violation of any emission limit or limits
stated in this permit as soon as possible, but no later than noon of the next working day, followed
by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the
Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs
4) The following emissions of non -criteria reportable air pollutants are estimated based upon the
process limits as indicated in this permit. This information is listed to inform the operator of the
Division's analysis of the specific compounds emitted if the source(s) operate at the permitted
limitations.
AIRS
Point
Pollutant
CAS #
Uncontrolled
Emissions
(lb/yr)
Controlled
Emissions
- (Ib/yr)
001
Benzene
71432
6,129
123
Toluene
108883
4,853
97
Ethylbenzene
100414
345
7
Xylenes
1330207
1,571
31
n -Hexane
110543
40,790
816
2,2,4-
Trimethylpentane
540841
148
3
Note: All non -criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year
(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice.
5) The emission levels contained in this permit are based on the following emission factors:
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
NOx
0.0036
0.0036
AP 42
CO
0.0165
0.0165
VOC
2.02
0.0404
ProMax
71432
Benzene
5.19 * 10-3
1.04 * 10-4
Page 12 of 14
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
CAS #
Pollutant
Uncontrolled
Emission Factors
lb/bbl
Controlled
Emission Factors
lb/bbl
Source
108883
Toluene
4.11 *
10-3
8.22 *
10-5
100414
Ethylbenzene
2.92 *
10-4
5.84 *
10-6
1330207
Xylene
1.33 *
10-3
2.66 *
10"5
110543
n -Hexane
3.45 *
10-2
6.91 *
10"4
540841
2'2'4-1.25
Trimethylpentane
*
10-4
2.51 *
10-6
Note: The controlled emissions factors for this point are based on a control efficiency of 98%. NOx and CO emission
factors are based on a gas heat content of 2,553 Btu/scf.
Actual controlled emissions shall be calculated using the following method:
Monthly Actual Emissions = [(Vtotat — VPLX) X EF x (100% — CE)] + [VPLX x EF]
where:
Vtorar = Total volume of condensate throughput (bbl)
VPLX = Total volume of condensate throughput while pilot light was not lit
or auto -igniter was not operational (bbl)
EF ' = Most recent approved uncontrolled emission factor (lb/bbl)
CE = 98%
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A
revised APEN must be submitted no later than 30 days before the five-year term expires. Please
refer to the most recent annual fee invoice to determine the APEN expiration date for each
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and
associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A)
when applicable.
8) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, NOx, n -Hexane, Total HAP
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC, NOx
MACT HH
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:
Page 13 of 14
COLORADO
Air Pollution Control Division
(Department ct Public Wealth & Env ronment
Dedicated to protecting and improving the health and environment of the people of Colorado
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix 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 14 of 14
C6oraolo Air Permitting Project
PRELIMINARY ANALYSIS-PROJECT SUMMARY
Project Details
Review Engineer: Ben Fischbach
Package 8: 414411
Received Date: 8/7/2019
Review Start Date: 9/19/2019
Section 01-Facility Information
Company Name: PDC Energy,Inc. Quadrant Section I Township Range
County AIRS ID: 123 NWSE 9 6N 66
Plant AIRS ID: A07R
Facility Name: McNear 10-9 Pad
Physical
Address/Location: . _ ; Y Range 664.1
County: Weld County
Type of Facility: Exploration&Production Well Pad
What industry segment?Oil&Natural Gas Production&Prodess ng { ,; ` .
Is this facility located in a NAAQS non-atta me t area? Yes '
If yes,for what pollutant? IA Carbon Monox de(CO) ❑Particulate Matter(PM) Q Ozone(NOx&SCC)
Section 02-Emissions Units In Permit Application
Emissions Self Cert
AIRs Point it Emissions Source Type Equipment Name Permit ti Issuance n Action Engineering Remarks
Control? Required?
Permit Initial
001 Condensate Tank TNK 1-6 Yes 19WE0810 1 Yes Issuance
Analysis pages hidden
in this workbook-see
PA for 19W E0811.CP1
for analysts of point
Permit Initial 002,
002 --:Liquid Loading LOAD-1 Yes 19WE0811 1 Yes Issuance
Section 03-Description of Project
Applicant proposes permitting of one condensate tank battery and one loadoutoperation at an O&G production facility which was newly constructed in the NAA in Weld County in
August,2019.
Facility/Project both Synthetic minor for VOC-project.requires Public Notice period.
Section 04-Public Comment Requirements
Is Public Comment Required? Yes
If yes,why? -_Requesting Synthetic Minor Permit
Section 05-Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes,for what pollutants?
If yes,attach a copy of Technical Services Unit modeling results summary.
Section 06-Facility-Wide Stationary Source Classification
Is this stationary source a true minor? No
Is this stationary source a synthetic minor? Yes
If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration(PSD) ✓ ' ,I
Title V Operating Permits(OP) 1 ./ Li LJ
Non-Attainment New Source Review(NANSR) ./ J
Is this stationary source a major source? No
If yes,explain what programs and which pollutants herr SO2 NOx CO VOC
PM2.5 PM10 TSP HAPs
Prevention Operating
of acing t Deterioration(PSD) n I I
Title V Operating Permits(OP) Ir;
Non-Attainment New Source Review(NANSR)
Coil{'("r1SaC? S≥vt≥" T= la lt(5� Ernissions invent )l y
001 Condensate Tank
Facility AIRs ID:
123
County
1078 001
Plant Point
Section 02 - Equipment Description Details
Detailed Emissions Unit Six (6)- 400 bbl Condensate Storage Tanks.
Description:
Emission Control Device Enclosed Flare.
Description: -
Requested Overall VOC & HAP Control
Efficiency %:
Section 03 - Processing Rate Information for Emissions Estimates
Primary Emissions - Storage Tank(s)
Actual Condensate Throughput =
Requested Permit Limit Throughput =
984,022 Barrels (bbl) per year
Actual Condensate Throughput While Emissions Controls Operating =
Requested Monthly Throughput =
984,022 Barrels (bbl) per year
1,180,848 Barrels (bbl) per year
10329) Barrels (bbl) per month
Potential to Emit (PTE) Condensate Throughput
Secondary Emissions - Combustion Device(s)
Heat content of waste gas =
Volume of waste gas emitted per BBL of liquids
produced =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
1,180,848 Barrels (bbl) per year
2553 Btu/scf
20.8845 scf/bbl
Will this storage tank emit flash emissions?
Heat Content based on weighted average of W &B and Flash streams from
Promae (weightedbased on relative flow rates).
•*: MM BTU per year
5510..' MM BTU per year
it MMBTU per year
Emission Factors
Condensate Tank
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Condensate
Throughput)
(Condensate
Throughput)
VOC
2.02
.• O404
Site Specific E.F..(,c) dec flash)
Benzene
5.19E-03
_..F 04
Site Specific E.F. ): , odes flash)
Toluene
4.11E-03
3.22E-03
Site Specific E.F. (o -dudes flash)
Ethylbenzene
2.92E-04
5 31E O£
Site Specific E.F. (includes flash)
Xylene
1.33E-03
__:._,.5
Site Specific E.c ):o€lodes flash)
n -Hexane
3.45E-02
..-_1.=-04
Site Specific EC. (includes flash)
224TMP
1.25E-04
.,.E-05
Site Specific E.F,(iodudes flash)
Control Device
Uncontrolled Uncontrolled
Pollutant
(lb/MMBtu) (Ib/bbi)
Emission Factor Source
(waste heat
combusted)
(Condensate
Throughput)
PM10
"3.0000
PM2.5
5 0000
NOx
0.0680
0.0036
AP -42 Chapter.13,51pdustrial Flares (NOx)
CO
0.3100
0.0165
AP -42 Chaptel ,SJOdustrial Flares (CO)
Section OS - Emissions Inventory
Potential to Emit
Actual Emissions
Requested Permit Limits
Requested Monthly Limits
Criteria Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
Controlled
(tons/year)
(tons/year) (tons/year)
(tons/year) (tons/year)
(lbs/month)
VOC
1192.48
993.12
-- _
119? c
PM10
00
21
0.0
60
._.l
PM2.5
:1 0
�-_.
0.0
-
NOx
CO
2.14
1.78
1.75
2.1
..,
3.76
9 13
8,13
9 8
Potential to Emit
Actual Emissions
Requested Permit Limits
Hazardous Air Pollutants
Uncontrolled
Uncontrolled Controlled
Uncontrolled Controlled
(lbs/year)
(lbs/year) (lbs/year)
(lbs/year) (lbs/year)
Benzene
5129
0137
102
5129
Toluene
1013
4014
81
-1003
.
Ethylbenzene
341
287
3
345
Xylene
1571
1309
26
ST:
11
n -Hexane
30790
33991
680
1;790
Sic
224 TMP
148
5233
2
118
1
Section 06 - Regulatory Summary Analysis
Regulation 3, Parts A, B
,,,,broe requires a permit
Regulation 7, Section XII.C, D, E, F
_s., ge tank rs subject to Regulation 7. Sectoo X3 CE
Regulation 7, Section XII.G, C
Storage Tank Is not taller( zv Regulation 7 ',echo:: /1 O
Regulation 7, Section XVll-B, C.1, C.3
Stcrag: tankss subject to Regulaton 7, Section Xs P. 8 7.1 S._.
Regulation 7, Section XVII.C.2
Storage tonic is subject to R, g =rate€ -
Regulation 6, Part A, NSPS Subpart Kb
Storage Tank is not.005:ect to NSPS PE
Regulation 6, Part A, NSPS Subpart 0000
Storage Tank is not ,oble.t to 0515 OW 1110
Regulation 8, Part E, MAT Subpart HH
Storage Tank i., not ...jets to MOM" laH I
(See regulatory applicability worksheet for detailed analysis)
2 of 6
K:\PA\2019\19W E0810.CP1
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 en "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 maybe appropriate to use an older site -specific sample.
If no, the permit will contain an "Initial Compliance" testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 05-01.
Does the company request a control device efficiency greater than 95%for a flare er 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
Site -specific emission factors based on a Promax sample which models the condensate tank only. Promax model was specified based on; an extended natural gas liquid analysis which was performed on
the pressurized liquid winch is transported into the condensate tanks at this facility. Extended natural gas liquid analysis was performed/provided by Alliance Source Testing, with a sample date of
7/19/19 and an analysis date of 7/22/19. The liquid sample was collected from a 'Gas Buster" at the McNear 10-9 facility, at a pressure of 18.9 psig (ambient = 12.3 psia), and a temperature of lotF.
Promax model which was originally submitted with this aopacation specified a separator pressure which was slightly higher than that reported on the sample analysis. I discussed this with operator, and.
discrepancy camefrom fact that, while operator specified a condensate tank pressure of 12.12 psia (local ambient), they left the overall "Protect" ambient pressure at 14.7 psia (sea level). Operator ran a
new version of the Promax model in which the overall ambient pressure was set to 12.12 psia, and the results showed that emissions did not change from initial model (this result likely has to do with the
sample analysis showing that the sample ten slightly outside of the phase envelope- I compared a similarly rills -specified model from a different project, and found that correcting the pressure (from a
sample which was collected on the others de of the phase envelope border) estimated less emissions (i.e the originally submitted model was more conservative), but was still negligible.). Given the fact
that specifying the pressures in the original models yielded more conservative results, will accept those emission factors and permit based on those values.
AIRS Point tt
001
Process X SCC Code
01 st
Section 09 - Inventory 5CC Coding and Emissions Factors
Uncontrolled
Emissions
Pollutant Factor Control % Units
PM10 0.00 0 lb/1,000 gallons condensate throughput
PM2.5 0.00 0 lb/1,000 gallons condensate throughput
NOx 0.09 0 lb/1,000 gallons condensate throughput
VOC 48.1 98 lb/1,000 gallons condensate throughput
CO 0.39 0 lb/1,000 gallons condensate throughput
Benzene 0.12 98 lb/1,000 gallons condensate throughput
Toluene 0.10 98 lb/1,000 gallons condensate throughput
Ethylbenzene 0.01 98 Ib/1,000 gallons condensate throughput
Xylene 0.03 98 lb/1,000 gallons condensate throughput
n -Hexane 0.82 98 lb/1,000 gallons condensate throughput
224 TMP 0.00 98 lb/1,000 gallons condensate throughput
3 of 6 K:\PA\2019\19WE0810.CP1
Condensate Tank Regulatory Analysis Worksheet
Colorado Re -Motion 3 Parts A and B -OPEN and Permit Requirements
,:, sa see eveniement neen
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greaterthan 2 TPY (Regulation 3, Part A, Section lt.D.1.a)?
2. 8 the construction date (service date) prtorto 12/30/2002 and not modified after 12/31/2002 (See PS Memo 05-01 Detintions 1.12 and1.14 and Section 2 for additional guidance en grandfather applicability)?
3. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOT greaterthan 10 TPY or CO emissions greater than 10 TM( (Regulation 3, Part B, Section 11.0.31?
NON -ATTAINMENT
L Are uncontrolled emissions from any criteria pollutants from this lndivldualsource greaterthan l TPY (Regulation 3, Part A, Section Il.D.l.a)?
2. la'd'e construction date (service date) prior to 12/30/2062 and not modified after l2/31/2002(See PS Memo 05-01 Definitions 1.12 and1.14 and Section 2 for additional guidance on grandfather applicability)?
3. Aretotal facility uncontrolled VOC emissions greaterthan 2 TPY, hoe greater than 5 TPV or CO emissions seater than 10 TPY (Regulation 3,153 3; Section 11.0.2)?
IVic..`r 1 . n a .r -.t
Colorado Regulation 7, Section XII.C-F
1. Isthiestorage tank located in the 8 -hr ozone control area or any ozone non -attainment area or attainment/maintenance
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?
As ,
-C-
Section 011.0.1 —General Requirements for Air Pollution Control Equipment —Prevention of Leakage
Section %R,C.2 —Emission Estimation Procedures
Section %R.0 —Emissions Control Requirements
Section XR.E— Monitoring
Section OR.F — Recordkeeping and Reporting
Colorado Regulation 7, Section %the
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. [..this storage tank exhibit"Flash" (e.g. storing non -stabilized liquids)emissions and have uncontrolled actual emissions greater than or equal to 2 tons per year VOC
Yom'-' W
Section X11.0.2- Emissions Control Requirements
Section XII.Ci —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 storagetank' 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 storagetank?
4. Are uncontrolled actual emissions' of this storage tank equal to orgreaterthan 6 tons per year VOC?
E
Section %VII.B— General Provisions for Air Pollution Control Equipment and Prevention of Emissions
Section XVII.C.1- Emissions Control and Monitoring Provisions
Section XVII.C.3 - Recordkeeping Requirements
5. Does the condensate storage tank contain only "stabilized" liquids?
Section %Vll.42 - 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 greaterthan or equal to 75 cubic meters (m') [5472 BBts]?
2. Does the storage vessel meet thefollowing exemption in bo.111h(d)(4)?
a. Does the vessel has a design capacity less than or equal to 1,589.874 NO r10,000 BBL] used forpetroleuni or condensatestored,processed, or treated prior to custodytransfer as defined in 6o.111b?
3. Was this condensate storagetank constructed,reconstructed, or modified (see definitions 40 CFR, 60.2) afterluly 23, 1984?
4. Does the tank meet the definition of "storage vessel"' in 60.1116?
5. Does the storage vessel stare a"volatile organic liquid (VOL)"' as defined in 60.1116?
G. Does the storage vessel meet any one of the following additional exemptions:
a. Is the. storagevessel a pressure vessel designedto operate in excess of 204.9 kPa [^29.7 pail and without emissions to the atmosphere (6o.11ob(d)(2))?; o
I. The design capacty is greater than or equalto 151 m' [`950 BBL] and stores a liquid with a maximum truevapor pressure' less than 3.5 kPa (6o.11ob(6))?r or
p The design capacity is greater than or equal to 75 he !'"472 Boy but less than 151 ma[5050 Bill and stores a liquid with a maximum tnsevaeor pressure' less than 15.0 kPa(6o.11ob(b)l?
Interns Te=e°s eossokirms• 3uP5rie
Subpart A, General Provisions
§60.111b - Emissions Control Standards for VOC
§60.113b -Testing and Procedures
460,1156- Reporting and Recordkeeping Requirements
§60.Si66 - Monitoring of Operations
40 045, Part 60, Subpart 0000, Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
1, Is this condensate storage vessel located at a facility in the onshore oil -and natural gas production segment, natural gas processing segment or natural gastransmusion and storage segment ofthe induery?
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 vesselgreeterthan or equal to 6 tons per year?
4. Does this condensate storage vessel meet the definition of "storage vessel"' per 60.5430?
S. Isthestorage vessel subject to and controlled in accordance with re mrements for stow evessels in 40 CFR Part 60 Subpart Kb or 40 CFR Part 63 Sub art HH?
Yet.
WAN
Q'k
Ong
Subpart A, General Provisions per§60.5425 Table 3
§66.5395- Emissions Control Standards -I. -00G
460 5413 -resting and Procedures
§60.5395(8) -Notification, Reporting and Recordkeeping Requirements
§60.50.6(c)- cand Closed Vent system Monitoring Requirements
460.5417 - Control Device Monitoring Requirements
[Nate: If a storage vessel is previously determined to be subjectta NIPS 0000 due to emissions above 6 tons per year VOCan the applicability determination date, it should remain subject to NSPS O000 per 60.6365(e)(2) even
If potential Von emissions drop below 6 tons par lead
40 CFR, Part 63, Subpart MACT NH, Oil and Gas Production Fealties
1. Is the storagetank located at an oil and natural gas production facility that meets either of the following criteria:
e. A tacilitythat processes, upgrades or stores hydrocarbon liquids' (63.760(a)(2)); OR
b. Afacility 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 delNered to a final end useri (63.76o(a)(3))?
2. Is thetank located ate facility that is major' for HAPs?
3. Goesthetank meet the definition of, "storagev sel" in 63.761?
4. Does thetank meet the definition of"storage vessel with the potential for flash emissions"' per63.761?
5. Is the tank subject to control requirements under 46 CFR Part 60, Subpart Kb or Sub art 0000?
13,3Joyee hnekns
Subpart A, General provisions per §63.764 (a) Table 2
063.766 - Emissions Control Standards
§63.773 -Monitoring
465.774- Recordkeeping
463.775 -Reporting
RACT Review
RACT review is required if Regulation 7 does not apply AND if the tank is in the non -attainment area. If the tank meets both criteria, then review PACT 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 particulars/Nation 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 Quality Control Commission regulations, the language of the statute of 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 terns of the Clean Air Act
and Air Quality Control Commission regulations, but this document dues not establish legally binding requirements in and ofitself
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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
SRC Energy, Inc.
County AIRS ID
123
Plant AIRS ID
A07B
Facility Name
McNear 10-9
History File Edit Date
09 September 2020
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
AIRS
ID
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
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
19WE0810
Condensate Tanks (6-400 bbl)
2.1
1192.5
9.8
26.9
2.1
23.9
9.8
0.5
New
002
19WE0811
Condensate Loadout
0.0
29.8
0.2
0.6
0.0
1.5
0.2
0.0
New
003
GP08
Produced Water Tanks (2-400 bbl)
0.1
17.2
0.6
1.2
0.1
5.9
0.6
0.1
New
004
GP02
RICE 1150 Hp
0.1
0.1
5.6
9.8
27.6
2.6
0.1
0.1
5.6
7.8
16.7
1.3
No change
005
GP02
RICE 550 Hp
0.1
0.1
39.5
3.8
66.4
0.5
0.1
0.1
2.7
3.8
8.0
0.5
No change
006
GP02
RICE 550 Hp
0.1
0.1
39.5
3.8
66.4
0.5
0.1
0.1
2.7
3.8
8.0
0.5
No change
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
FACILITY TOTAL
0.3
0.3
0.0
0.0
86.8
1256.9
0.0
171.0
32.5
0.3
0.3
0.0
0.0
13.2
46.7
0.0
43.3
3.0
VOC: Syn Minor (PSD, NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (OP)
HAPS: Syn Minor B, T, X, HCHO & Total
HH: Syn Minor + affected Area
7777• Sun Miner
Permitted Facility Total
0.2
0.2
0.0
0.0
10.5
42.9
0.0
35.3
2.4
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.2
0.2
0.0
0.0
10.5
42.9
0.0
35.3
Pubcom & modeling (not) required based on (A
change in emissions)
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Pe mitted VOC emiss ons (point and fugitive)
46.7
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
42,9
Page 5 of 6
Printed 9/9/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
123
AO7B
McNear 10-9
Emissions - uncontrolled (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL (tpy)
001
19WE0810
Condensate Tanks (6-400 bbl)
6129
4853
345
1571
40790
148
26.9
002
19WE0811
Condensate Loadout
100
84
6
28
1000
4
0.6
003
GP08
Produced Water Tanks (2-400 bbl)
929
725
56
192
592
0
1.2
004
GP02
RICE 1150 Hp
3773
720
443
38
215
2.6
005
GP02
RICE 550 Hp
732
100
94
56
109
0.5
006
GP02
RICE 550 Hp
732
100
94
56
109
0.5
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL (tpy)
2.6
0.5
0.3
3.7
2.8
0.2
0.9
21.2
0.2
0.1
32.5
Emissions with controls (lbs per year)
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL (tpy)
001
19WE0810
Condensate Tanks (6-400 bbl)
123
97
7
31
816
3
0.5
002
19WE0811
Condensate Loadout
5
4
0
1
50
0
0,0
003
GP08
Produced Water Tanks (2-400 bbl)
46
36
3
10
30
0
0.1
004
GP02
RICE 1150 Hp
1110
720
443
38
215
1.3
005
GP02
RICE 550 Hp
732
100
94
56
109
0.5
006
GP02
RICE 550 Hp
732
100
94
56
109
0.5
0,0
0.0
0.0
0.0
0.0
0.0
TOTAL (tpy)
1.3
0.5
0.3
0.2
0.1
0.0
0.0
0.4
0,2
0.0
3.0
6
19WE0810.CP1
9/9/2020
,,,,,,,,.,�.��•�,�- COLORADO
Nt
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE0811 Issuance: 1
Date issued:
Issued to: PDC Energy, Inc.
Facility Name: McNear 10-9 Pad
Plant AIRS ID: 123/A07B
Physical Location: NWSE SEC 9 T6N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Emissions Control
ID Point Equipment Description Description
LOAD-1 002 Truck loadout of condensate by Enclosed Flare
submerged fill
This permit is granted subject to all rules and regulations of the Colorado Air Quality Control
Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to
the specific general terms and conditions included in this document and the following specific terms
and conditions.
REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION
1. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, compliance with the conditions contained in this permit must be
demonstrated to the Division. It is the owner or operator's responsibility to self-certify
compliance with the conditions. Failure to demonstrate compliance within 180 days may
result in revocation of the permit. A self certification form and guidance on how to self-
certify compliance as required by this permit may be obtained online at
www.colorado.gov/cdphe/air-permit-self-certification. (Regulation Number 3, Part B, Section
III.G.2.)
2. This permit must expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source within 18
months after either, the date of issuance of this construction permit or the date on which
such construction or activity was scheduled to commence as set forth in the permit
application associated with this permit; (ii) discontinues construction for a period of eighteen
months or more; (iii) does not complete construction within a reasonable time of the
Page 1 of 11
COLORADO
Air Pollution Control Division
Department at Pubttc Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
estimated completion date. The Division may grant extensions of the deadline. (Regulation
Number 3, Part B, Section III. F.4. )
3. The operator must retain the permit final authorization letter issued by the Division, after
completion of self -certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID
AIRS
Point
Tons per Year
Emission
Type
pM2.5
NOX
VOC
CO
LOAD -1
002
---
---
1.5
---
Point
Note: See "Notes to Permit Holder" for information on emission factors and methods used to calculate limits.
Facility -wide emissions of each individual hazardous air pollutant 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 site responsibility for Division review.
5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. The owner or operator must submit
an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any
other method of calculating emissions.
6. The owner or operator must track emissions from all insignificant activities at the facility on
an annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must
be made available to the Division for inspection upon request. For the purposes of this
condition, insignificant activities are defined as any activity or equipment, which emits any
amount but does not require an Air Pollution Emission Notice (APEN) or is permit exempt.
(Regulation 3, Part C. II.E.)
E. )
Page 2 of 11
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC.
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.)
Equipment
ID
AIRS
Point
Control Device
Pollutants Controlled
LOAD -1
002
Enclosed Flare
VOC and HAP
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 rate must be maintained by the owner or operator
and made available to the Division for inspection upon request. (Regulation Number 3, Part
B, Section II.A.4)
Process/Consumption Limits
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
LOAD -1
002
Condensate Loaded
118,085 barrels
The owner or operator must calculate 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. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
the source. During periods of startup, process modification, or adjustment of control
equipment visible emissions shall not exceed 30% opacity for more than six minutes in any
sixty consecutive minutes. (Regulation Number 1, Section II.A.1. It 4.)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
Page 3 of 11
COLORADO
Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution
control equipment. Compliance with Section II.C.5. must be achieved in accordance with the
following schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal
to 5,000 barrels per year on a rolling 12 -month basis must control emissions from
loadout upon exceeding the loadout threshold.
12. Storage tanks must operate without venting at all times during loadout. (Regulation Number
7, Part D, Section II.C.5.a.(ii))
13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section
II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport
vehicles and to route the vapors to the storage tank or air pollution control
equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back -pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless
loadout occurs less frequently, then as often as loadout is occurring.
14. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect
the facility within 24 hours after loadout to confirm that all storage tank thief hatches
(or other access point to the tank) are closed and latched.
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
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
that includes, at a minimum, operating procedures for each type of loadout control
system.
15. The owner or operator must retain the records required by Regulation Number 7, Part D,
Section II.C.5.a.(v) for at least two (2) years and make such records available to the Division
upon request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
Inspections, including a description of any problems found and their resolution,
required under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
Records of the infeasibility of observation of loadout.
Records of the frequency of loadout.
Records of the annual training program, including the date and names of persons
trained.
16. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
17. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator
of oil and natural gas operations and equipment at or upstream of a natural gas processing
plant in Colorado must submit a single annual report that includes actual emissions and
specified information in the Division -approved report format. The information included in the
annual report must be in accordance with the general reporting requirements of Regulation
Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter,
owners or operators must maintain the information according to Regulation Number 7, Part D,
Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V)
OPERATING Et MAINTENANCE REQUIREMENTS
18. 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 with the requirements of this permit. Revisions
to your OEtM plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
Page 5 of 11
COLORADO
Air Pollution Control Division
Department of Public Health El Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
19. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the
Division or other state or federal requirement.
ADDITIONAL REQUIREMENTS
21. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
Section 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 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.
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.
22. The requirements of Colorado Regulation Number 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).
Page 6 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
GENERAL TERMS AND CONDITIONS
23. 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.
24. 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.
25. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
representations made by the owner or operator or owner or operator's agents. It is valid only
for the equipment and operations or activity specifically identified on the permit.
26. 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.
27. 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.
28. 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.
Page 7 of 11
COLORADO
Air Pollution Control Division
Department of Public Health fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
29. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By: DRAFT
Ben Fischbach
Permit Engineer
Permit History
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
New Synthetic Minor Facility
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 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.
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
100
5
Toluene
108883
84
4
Ethylbenzene
100414
6
0
Xylenes
1330207
28
1
n -Hexane
110543
1,000
50
224 TMP
540841
4
0
Note: All non -criteria reportable pollutants in the table above with uncontrolled emiss'on 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
Au 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:
Pollutant
CAS #
Uncontrolled
Emission
Factors
lb/bbl
Controlled
Emission
Factors
lb/bbl
Source
NOx
7.35 *
10-4
7.35 *
10-4
AP -42: Ch.
13.5
CO
3.35 *
10-3
3.35 *
10"3
VOC
5.05 *
10-1
2.53 *
10"2
ProMax/AP-
42: Ch.
5.2,
Equation 1
Benzene
71432
8.43 *
10-4
4.22 *
10-5
Toluene
108883
7.14 *
10-4
3.57*
10-5
Ethylbenzene
100414
5.48 *
10"5
2.74 *
10"6
Xylene
1330207
2.37 *
10-4
1.18 *
10-5
n -Hexane
110543
8.47 *
10 3
4.23 *
10-4
224 TMP
540841
2.99 *
10"5
1.50 *
10-6
The uncontrolled VOC emission factor was calculated using AP -42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 18.5 psia
M (vapor molecular weight) = 45.73 lb/lb-mot
T (temperature of liquid loaded) = 526 °R
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated
by multiplying the VOC emission factor by the ratio of the mass fraction of each NCRP in the
vapors to the mass fraction of VOC in the vapors.
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
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
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
emissions point associated with this permit. For any questions regarding a specific expiration date
call the Division at (303)-692-3150.
7) This facility is classified as follows:
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC, CO, NOx, n -Hexane, Total HAP
PSD
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC, NOx
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://www.ecfr.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A - Subpart UUUU
NSPS
Part 60, Appendixes
Appendix A - Appendix 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 11 of 11
Co orlde Air PE'rrni'th ng Project
PRELIMINARY ANALYSIS - PROJECT SUMMARY
Project Details
Review Engineer: Ben Fischbach
Package It: 414411
Received Date: 8/7/2019
Review Start Date: 9/19/2019
Section 01- Facility Information
Company Name: PDC Energy, Inc.
County AIRS ID: 123
Plant AIRS ID: A078
Facility Name: McNear 10-9 Pad
Physical
Address/Location _ . .....
County:
Type of Facility: Exploration & Production Well Pad
What industry segment? Oil & Natural Gas Production & Processing
Is this facility located in a NAAQS non -attainment area? Yes
If yes, for what pollutant? D Carbon Monoxide (CO)
Weld County
Section 02- Emissions Units In Permit Application
ElParticulate Matter (PM)
Quadrant
Section
Township
Range
NWSE
9
6N
66
El Drone (NOx & v0C)
AIRs Point #
Emissions Source Type
Equipment Name
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
001
Condensate Tank
TNI(1-6
Yes
19WE0810
1
Yes.
Permit Initial
Issuance
Analysis pages
hidden in this
workbook - see PA
for 19WE0810.CP1
for analysis of point
001.
002
Liquid Loading
LOAD -1
Yes
19WE0811
1
Yes
Permit Initial
Issuance
Section 03 - Description of Project
Applicant proposes permitting of one condensate tank battery and one Ioadout operation at an O&G production facility which was newly constructed in the NAA in Weld County in August, 2019.
Facility/Project both Synthetic minor for VOC - project requires Public Notice period.
Section 04- Public Comment Requirements
Is Public Comment Required? Yes
If yes, why? Requesting Synthetic Minor Permit
Section 05- Ambient Air Impact Analysis Requirement
Was a quantitative modeling analysis required? No
If yes, for what pollutants?
If yes, attach a copy of Technical Services Unit modeling results summary.
Section 06- Facility -Wide Stationary Source Classification
Is this stationary source a true minor?
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)
No
Yes
S02 NOx CO VOC PM2.5 f PM10 TSP HAPs
J
Is this stationary source a major source? No
If yes, explain what programs and which pollutants herr SO2 NOx CO VOC PM2.5 PM10 TSP HAPs
Prevention of Significant Deterioration (PSD)
Title V Operating Permits (OP) [
Non -Attainment New Sourm Review (NANSR)
ii•ioroca:tcr,. Loai:; _ _ :1.SSi6:'S love. -.: ;
002 Liquid Loading
Facility AIRs ID:
123
County
AO7B 002.
Plant Point
Section 02- Equipment Description Details
Detailed Emissions Unit
Description:
Emission Control Device
Description:
Is this loadout controlled?
Collection Efficiency:
Control Efficiency:
Condensate loadout from storage tanks to trucks.
ECD
Requested Overall VOC& HAP Control Efficiency %:
Section 03 - Processing Rate information for Emissions Estimates
Primary Emissions- Hydrocarbon Loadout
Actual Volume Loaded =
Requested Permit Limit Throughput= 118,085 Barrels (bbl) per year
Potential to Emit (PTE) Volume Loaded = 118,085 Barrels (bbl) per year
100,0
95
98,402 Barrels (bbl) per year
Actual Volume Loaded While Emissions Controls Operating = 68,402 Barrels (bbl) per year
Requested Monthly Throughput= 10029 Barrels (bbl) per month
Secondary Emissions - Combustion Device(s)
Heat content of waste gas=
Volume of waste gas emitted per year =
Actual heat content of waste gas routed to combustion device =
Requested heat content of waste gas routed to combustion device =
2582 Btu/scf
> .. set/year
Potential to Emit (PTE) heat content of waste gas routed to combustion device =
Section 04- Emissions Factors & Methodologies
Does the company use the state default emissions factors to estimate env
Are the emissions factors based on a stabilized hydrocarbon liquid sample drawn at the facility
being permitted?
Loading Loss Equation
L =12,46*S*P*M/T
Yes
_ _• MMBTU per year
MMBTU per year
MM BTU per year
*** SEE TECHNICAL ANALYSIS NOTES 000
Factor
Meaning
Value
Units
Source
5
Saturation Factor
...,„//Jy'„y,,_
AP -42 Chapter 5[2 Table 5.21 Submerged Loading: Dedicated Normal Service'(5=0.6)
P
True Vapor Pressure
18.5
psia
ProMax Stream Callous
M
Molecular Weight of Vapors
45.73
Ib/Ib-mol
ProMax.
T
Liquid Temperature
525.67
Rankine
Avg Ambient Temp
L
Loading Losses
12,0317561)
lb/1000 gallons
.. 5t7> ,: lb/bbl
Component
Mass Fraction
Emission Factor
Units
Source
Benzene
0.0016687 ,-
0.00084325
lb/bbl
ProMax
Toluene
0.0014128
0.0007139.36
lb/bbl
ProMax
Ethylbenzene,
0.00010849 '.
''
i •4823'>E 05
Ib/bbl
`
ProMax
Xylene
0.0004682.
00002.3„53;
Ib/bbl
ProMax
n -Hexane
0.01676 -
0.80846639d
lb/bbl
ProMax
224 TMP
=
0.000059241
294505E-051b/bbl
ProMax
Emission Factors
Hydrocarbon Loadout
Emission Factor Source
Pollutant
Uncontrolled Controlled
(lb/bbl) (lb/bbl)
(Volume Loaded)
(Volume
Loaded)
VOC
5.02E al
...AN Oe
Site Specific AP -42: Chapter 5.2, Equation
Site Specific -AP -42: Chapter 5.2, Equation l'
Site Specific -AP -42: Chapter 5.2, Equalso1
Site Specific- AP -42: Chapter 5.2, Equat an 1
Site Specific -:AP -42: Chapter 5.2;.Equation .1
Site Specific - AP -42: Chapter 5.2, Equation 1
Site Specific -AP -42: Chapter 5.2, Equation l:
Benzene
:3tt1=14
-i 2?E•OS
Toluene
. 14134
?S7£.95
Ethylbenzene
i 22.1 ".S
2.Y?E-06
Xylene
2.217E n4
2.18E 05
n -Hexane
2.47£ 03
4.2;004
224TMP
_ 55? 05
.1.50S,2.
Pollutant
Control Device
Emission Factor Source
Uncontrolled Uncontrolled
(lb/MM Btu) (lb/bbl)
(waste heat combusted)
(Volume
Loaded)
PM10
0290E*ut
ter 3.5 Mai a• i
A _K-er 13.51ndustrial'Fla S _
PM2.5
0.00F •00
SOx
0 301 M0
NOx
0.0680
7 35E 04
CO
0.3100
"t ;5t,,
2 of6
K:\PA\2019\19 W E0811. C P1
Hydrocarbon Loadout Emiss,ons Inventory
Section 05 Emissions Inventory
Criteria Pollutants
Potential to Emit
Uncontrolled
(tons/year)
Actual Emissions
Uncontrolled Controlled
(tons/year) (tons/year)
Requested Permit Limits
Uncontrolled Controlled
(tons/year) (tans/year)
Requested Monthly Limits
Controlled
(lbs/month)
PM10
PM25
SOx
I NOx
VOC
CO
0 C
000
000
OCR
00E
0
090
000
000
O 0
Dun
0
000
901.
030
000
C30
0
004
C04
004
00
00
7
29 84
24 38
12
29 8
1 5
253
023
C16
016
02
02
34
Hazardous Air Pollutants
Potential to Emit
Uncontrolled
(Ibs/year)
Actual Emissions
Uncontrolled Controlled
(Ibs/year) Ohs/year)
Requested Permit Limits
Uncontrolled Controlled
(Ibs/year) (Ibs/year)
I
Benzene
Toluene
Ethylbenzene
Kylene
n Hexane
224 TMP
100
33
4
102
5
84
70
4
34
6
5
3
5
0
28
23
z
23
1
vGtO
833
42 -
1000
50
4
3
0
4
0
()
Section 06 Regulatory Summary Analysis
Regulation 3 Parts A B
5ni. ce req.n es a I el m
RACT Regulation 3 Part B Section III D 2 a
(See regulatory applicability worksheet for detailed analysis)
'he ioadout rius— opera`e with sabn arced fill and loaoout em ssions mu<t be cured o flare to satisfy PACT
Section 07 Initial and Periodic Sampling and Testing Requirements
Does the company request a control device efficiency greater than 95/ for a flare or combustion deviceo
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 _ _
••• While the operator did submit a stabilized oil sample along with project the site specific emission factors were estimated based on the sales oil/condensate stream from a Promax model I compared those operator
calculateddvalues to those calculated using the stabilized oil sample Using parameters from Promax fesults in significantly more conservative emission factors which I discussed with the operator The operator desires to
maintain'these more conservative emission factorsat this time which is acceptable ••• I r
HAP emission factors calculated in PA are yightly different but within rounding error Will base emissions and permit on those emission factors submitted by the operator in the APEN
Per APEN Contingency loading of condensate from storage tanks Truck loading emissions controlled by ECD with DRE of 95% Truck loading emissions are only expected to occur during LACT unit downtime
I`
Section 09 Inventory SCC Coding and Emissions Factors
AIRS Point
002
Process 9 SCC Code
01 a-00 001 32 C do O i Sabmer9cd Loan i 15 Ta n ai Sc-tiec (S=0 6)
r
Uncontrolled
Emissions
Pollutant Factor Control 9' Units
PM10 0 CO 0 lb/1 000 gallons transferred
PM2 5 0 00 0 lb/1 000 gallons transferred
SOx 000 9 lb/1 000 gallons transferred
NOx 0 0< 0 lb/1 000 gallons transferred
VOC 12 0 05 lb/1 000 gallons transferred
CO 0 00 0 Ib/1000 gallons transferred
Benzene ' 002 / 9. lb/1 000 gallons transferred
Toluene 002 90 lb/1 000 gallons transferred
Ethylbenzene 3 03 95 lb/1 000 gallons transferred
Kylene 0 0a 95 lb/1 000 gallons transferred
n Hexane 0 ZC 95 lb/1 000 gallons transferred
224 TMP 0 00 93 lb/1 000 gallons transferred
l
3 of 6 K \PA\2019\19WE0811 CP1
Hydrocarbon Loadout Regulatory Analysis Worksheet
Colorado Regulation 3 Parts A and B - APEN and Permit Requirements.
ATTAINMENT
1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY (Regulation 3, Part A, Section 11:0.1.0)?
2. Is the loadout located at an exploration and production site le.g., well pad) (Regulation 3, Part B, Section II.D,1.I)?
3. - Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
5. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facility uncontrolled VOC emissions greater than 5 TPY, NOx greater than 10TPY or CO emissions greater than lO TPY (Regulation 3, Part e, Section 11.0.3)?
'V Ivve indicated -h t uvice is __ Area
NON -ATTAINMENT
1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1 TPY (Regulation 3, Part A, Section II.D.1.a)?
2. Is the loadout located at an exploration and production site(e.g., well pad) (Regulation 3, Part B, Section Il.D.1.1)?
3. Is the loadout operation loading less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis?
4. Is the loadout operation loading less than 6,750 bbls per year of condensate via splash fill?
S. Is the loadout operation loading less than 16,308 bbls per year of condensate via submerged fill procedure?
6. Are total facil0y uncontrolled VOC emissions from the greater than 2 TPY, NO3 greater than 5 TPY or CO emissions greater than 10 TPY (Regulation 3, Part B, Section 11.D.2)?
Yes
Yes
No
No...:=r':....
N'
Yes
7. RACT- Are uncontrolled VOC emissions from the loadout operation greater than 20 tpy (Regulation 3, Part B, Section lliD.2.a)?
ITiLs iossoui_ suss., MIan A iiaz_, mui of[E"__s satisfy RACT.
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 ether legally binding requirement and is not legally enforceable. In the event of any conflict between the language of this document and the language of the Clean Air Act„ its implementing
regulations, and Air Quality Control Commission regulations, the language of the statute or regulation will control. The use of non -mandatory language such as "recommend,""may,""should,"and tan," 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 establish legally binding requirements in and of itself.
yes
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The loadou
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
SRC Energy, Inc.
County AIRS ID
123
Plant AIRS ID
A07B
Facility Name
McNear 10-9
History File Edit Date
09 September 2020
Ozone Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year)
EMISSIONS With Controls (tons per year)
AIRS
PERMIT
Description
PM10
PM2.5
ID VOC HAPs
H2S
SO2
NOx
VOC
Fug
CO
Total
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
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
19WE0810
Condensate Tanks (6-400 bbl)
2.1
1192.5
9.8
26.9
2.1
23.9
9.8
0.5
New
002
19WE0811
Condensate Loadout
0.0
29.8
0.2
0.6
0.0
1.5
0.2
0.0
New
003
GP08
Produced Water Tanks (2-400 bbl)
0.1
17.2
0.6
1.2
0.1
5.9
0.6
0.1
New
004
GP02
RICE 1150 Hp
0.1
0.1
5.6
9.8
27.6
2.6
0.1
0.1
5.6
7.8
16.7
1.3
No change
005
GP02
RICE 550 Hp
0.1
0.1
39.5
3.8
66.4
0.5
0.1
0.1
2.7
3.8
8.0
0.5
No change
006
GP02
RICE 550 Hp
0.1
0.1
39.5
3.8
66.4
0.5
0.1
0.1
2.7
3.8
8.0
0.5
No change
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
FACILITY TOTAL
0.3
0.3
0.0
0.0
86.8
1256.9
0.0
171.0
32.5
0.3
0.3
0.0
0.0
13.2
46.7
0.0
43.3
3.0
VOC: Syn Minor (PSD, NANSR and OP)
NOx: Syn Minor (NANSR and OP)
CO: Syn Minor (OP)
HAPS: Syn Minor B, T, X, HCHO & Total
HH: Syn Minor + affected Area
7777• Svn Miner
Permitted Facility Total
0.2
0.2
0.0
0.0
10.5
42.9
0.0
35.3
2.4
Excludes units exempt from permits/APENs
(A) Change in Permitted Emissions
0.2
0.2
0.0
0.0
10.5
42.9
0.0
35.3
Pubcom & modeling (not) required based on (A
change in emissions)
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Pe mitted VOC emiss ons (point and fugitive)
46.7
-
Facility is eligible for GP02 because < 90 tpy
Project emissions less than 25/50 tpy
42.9
Page 5 of 6
Printed 9/9/2020
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
123
A07B
McNear 10-9
Emissions - uncontrolled (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL (tpy)
001
19WE0810
Condensate Tanks (6-400 bbl)
6129
4853
345
1571
40790
148
26.9
002
19WE0811
Condensate Loadout
100
84
6
28
1000
4
0.6
003
GP08
Produced Water Tanks (2-400 bbl)
929
725
56
192
592
0
1.2
004
GP02
RICE 1150 Hp
3773
720
443
38
215
2.6
005
GP02
RICE 550 Hp
732
100
94
56
109•
0.5
006
GP02
RICE 550 Hp
732
100
94
56
109
0.5
0.0
0.0
0.0
0.0
0.0
0.0
TOTAL (tpy)
2.6
0.5
0.3
3.7
2.8
0.2
0.9
21.2
0.2
0.1
32.5
Emissions with controls (Ibs per year
POINT
PERMIT
Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
TOTAL (tpy)
001
19WE0810
Condensate Tanks (6-400 bbl)
123
97
7
31
816
3
0.5
002
19WE0811
Condensate Loadout
5
4
0
1
50
0
0.0
003
GP08
Produced Water Tanks (2-400 bbl)
46
36
3
10
30
0
0,1
004
GP02
RICE 1150 Hp
1110
720
443
38
215
1.3
005
GP02
RICE 550 Hp
732
100
94
56
109
0.5
006
GP02
RICE 550 Hp
732
100
94
56
109
0,5
0,0
0.0
0.0
0,0
0.0
0.0
TOTAL (tpy)
1.3
0.5
0.3
0.2
0.1
0.0
0.0
0.4
0.2
0.0
3.0
6
19WE0811.CP1
9/9/2020
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. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your
emission source does not fall into this category, there may be a more specific APEN available for your source (e.g.
crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading, etc.). In addition, the General
APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all
available APEN forms and associated addendum forms can be found on the Air Pollution Control Division (APCD)
website 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:
"hlre.l,G 8>' QJ AIRS ID Number: / � !Aar', I ' Gl (
[Leave blank unless APCD has already assigned a permit ?, and AIRS ID]
Section 1 - Administrative Information
Company Name': SRC Energy, Inc.
Site Name: McNear 10-9 Pad
Site Location: NWSE Sec. 9 T6N R66W
Mailing Address:
(Include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634
Site Location
County: Weld
NAICS or SIC Code: 211111
Contact Person:
Phone Number:
E -Mail Address2:
Brad Rogers
(970) 475-5242
brogers@srcenergy.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.
'19#(!
Form APCD-205 Condensate Storage Tank(s) APEN Revision 3/2019 1 I
AV
COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit ri and AIRS ID
Section 2 - Requested Action
▪ NEW permit OR newly -reported emission source
0 Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ GP08
If General Permit coverage is requested, the General Permit registration fee of $312.50 must be
submitted along with the APEN filing fee.
-OR-
❑ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other (describe below)
OR
• APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
• APEN submittal for permit exempt/grandfathered source
❑ Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PIE)
Additional Info & Notes:
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):
For existing sources, operation began on:
Storage of condensate from production wells
TNK 1-6
For new or reconstructed sources, the projected start-up date is: 05/09/2019
Normal Hours of Source Operation: 24
Storage tank(s) located at:
hours/day 7 days/week 52
weeks /year
❑✓ Exploration a Production (E&P) site ❑ Midstream or Downstream (non EEcP) site
Will this equipment be operated in any NAAQS nonattainment area?
Yes
No
O
■
Are Flash Emissions anticipated from these storage tanks?
Yes
No
Q
■
Is the actual annual average hydrocarbon liquid throughput ≥ 500 bbl/day?
Yes
No
p
■
If "yes", identify the stock tank gas -to -oil ratio:
0.00372
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
O
No
0
Are you requesting ≥ 6 ton/yr VOC emissions (per storage tank), or are uncontrolled actualIS
emissions ≥ 6 ton/yr (per storage tank)?
Yes
No
■
Form APCD-2O5 Condensate Storage Tank(s) APEN - Revision 3 /2019
�� COLORADO
0 Upward
❑ Horizontal
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit n and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount
(bbl/year)
Requested Annual Permit Limits
(bbl/year)
Condensate Throughput:
984,022
1,180, 848
From what year is the actual annual amount?
2019
Average API gravity of sales oil: 43.6 degrees
❑ Internal floating roof
Tank design: 0 Fixed roof
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)
TNK 1-6
6
2,400
04/2019
05/2019
Wells Serviced by this Storage Tank or Tank Battery6 (HIP Sites Ony)
API Number
Name of Well
Newly Reported Well
05
- 123
- 47512
McNear 7C -7-L
SI
05
- 123
- 47513
McNear 28C -7-L
IS
05
- 123
- 47514
McNear 25N -7A -L
l7
05
- 123
- 47515
McNear 2N -7A -L
SI
05
- 123
- 47516
McNear 21 N -7A -L
SI
5 Requested values will become permit limitations. Requested limit(s) should consider future growth.
6 The E&P Storage Tank APEN Addendum (Form APCD-212) should be completed and attached when additional space is needed to
report all wells that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.50068/-104.78163
Operator Stack
ID No.
Discharge Height Above
Ground Level (feet)
Temp.
(°F)
Flow Rate
(ACFM)
Velocity
(ft/sec)
IES-1
27.21
1,076
451.4
i 0.16
Indicate the direction of the stack outlet: (check one)
O Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular
O Square/rectangle
O Other (describe):
❑ Upward with obstructing raincap
Interior stack diameter (inches): 92
Interior stack width (inches): Interior stack depth (inches):
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 3/2019
®� COLORADO
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:
Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented):
Make/Model:
Combustion
Device:
Pollutants Controlled: VOCs and HAPs
Rating: 276.59
Type: Enclosed Combustor
Requested Control Efficiency:
Manufacturer Guaranteed Control Efficiency:
Minimum Temperature: 1,076°F
MMBtu/hr C
Make/Model: (4) 96" I ES
98
98
%
Waste Gas Heat Content:
Constant Pilot Light: E Yes ❑ No Pilot Burner Rating:
2,553
0.058
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)? 18.9 psig
Describe the separation process between the well and the storage tanks:
(12) 36" Worthington 3 -phase separators each rated at 0.5 MMBtu/hr,
(6) non -fired 2 -phase vertical separators, and
(1) 72" Dragon Manufacturing gas buster rated at 1.00 MMBtu/hr.
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 3/2019
Aftwir COLORADO
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit a and AIRS ID)
Section 8 - Emissions Inventory Information
Attach all emissions calculations and emission factor documentation to this APEN form.
If multiple emission control methods were identified in Section 6, the following table can be used to state the
overall (or combined) control efficiency (% reduction):
Pollutant
Description of Control Method(s)
Overall Requested Control
Efficiency
(% reduction in emissions)
VOC
Enclosed Combuster
98%
NOx
CO
HAPs
Enclosed Combuster
98%
Other:
From what year is the following reported actual annual emissions data? 201 9
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions8
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
VOC
2.020
Ibs/bbl
ProMax
993.70
19.87
1,192.46
23.85
NOx
0.068
Ib/MMBtu
AP -42
N/A
1.78
N/A
2.16
CO
0.31
Ib/MMBtu
AP -42
N/A
8.13
N/A
9.84
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor?
Actual Annual Emissions
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions8
(pounds/year)
Benzene
71432
5.19E-03
lbs/bbl
ProMax
5,107.08
102.14
Toluene
108883
4.11E-03
Ibs/bbl
ProMax
4,044.33
80.89
Ethylbenzene
100414
2.92E-04
Ibs/bbl
ProMax
287.33
5.75
Xylene
1330207
1.33E-03
lbs/bbl
ProMax
1,308.75
26.17
n -Hexane
110543
3.45E-02
Ibs/bbl
ProMax
33.990.86
679.82
2,2,4-
Trimethylpentane
540841
1.25E-04
lbs/bbl
l
ProMax
123.00
2.46
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-2O5 Condensate Storage Tank(s) APEN - Revision 3/2019
®Y COLORADO
Permit Number:
AIRS ID Number:
I 1
[Leave blank unless APCD has already assigned a permit tl 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.
ze, 19
Signature of Legally Authorized Person (not a vendor or consultant)
Brad Rogers
Name (print)
Date
Health and Environmental Manager
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 Tanks) APEN - Revision 3/2019
6 I �® COLORADO
E&P Storage Tank Air Pollutant Emissions Notice (APEN) Addendum Form'
Company Name:
SRC Energy, Inc.
Source Name:
McNear 10-9 Pad - Condensate Tanks
Emissions Source AIRS ID2:
123 I/40113/4o t
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number
Name of Well
Newly Reported Well
05 - 123 - 47517
McNear 2C -7-L
/1
05 - 123 - 47518
McNear 25C -7-L
11
05 - 123 - 47519
McNear 28N -7B -L
/ZI
05 - 123 - 47520
McNear 2N -7C -L
►,1
05 - 123 - 47521
McNear 21 N -7C -L
05 - 123 - 47522
McNear 7N -7C -L
/1
05 - 123 - 47523
McNear 7N -7B -L
/1
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
I
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
- -
❑
Footnotes:
I Attach this addendum to associated APEN form when needed to report additional wells.
If this is a newly report source that has not been assigned an AIRS ID by the APCD, enter
N/A
Form APCD-212
APCD-212-COND Tank-Addendum.docx
Hydrocarbon Liquid Loading APEN
Form APCD-208
Air Pollutant Emission Notice (APEN) and
Application for Construction Permit
All sections of this APEN and application must be completed for both new and existing facilities, including APEN
updates. Incomplete APENs will be rejected and will require re -submittal. Your APEN will be rejected if it is
filled out incorrectly, is missing information, or lacks payment for the filing fee. The re -submittal will require
payment for a new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. If your emission unit does not fall into this category,
there may be a more specific APEN for your source (e.g. amine sweetening unit, glycol dehydration unit,
condensate storage tanks, 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 can be found on the Air Pollution
Control Division (APCD) website at: www.colorado.gov/cdphe/apcd.
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:
AUG - 7 X)19
//9L/E-067H AIRS ID Number: 123 /AC/Y.7g / 661. -
[Leave blank unless APCD has already assigned a permit r and AIRS ID[
Section 1 - Administrative Information
Company Name': SRC Energy, Inc.
Site Name: McNear 10-9 Pad
Site Location: NWSE Sec. 9 T6N R66W
Mailing Address:
(Include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634
Site Location
County: Weld
NAICS or SIC Code: 211 111
Contact Person: Brad Rogers
Phone Number: (970) 475-5242
E -Mail Address2: brogerS@srcenergy.com
'Use the full, legal company name registered with the Colorado Secretary of State. This is the company name that wilt 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.
g/P-LOO
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019
alt) COLORADO
Permit Number: AIRS ID Number:
[Leave blank unless APCD has already assigned a permit a and AIRS ID]
Section 2 - Requested Action
❑r NEW permit OR newly -reported emission source
❑✓ Request coverage under construction permit
0 Request coverage under General Permit GP07
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 fuel or equipment 0 Change company name3
❑ Change permit limit 0 Transfer of ownership' 0 Other (describe below)
-OR -
❑ APEN submittal for update only (Note blank APENs will not be accepted)
- ADDITIONAL PERMIT ACTIONS -
El Limit Hazardous Air Pollutants (HAPs) with a federally -enforceable limit on Potential To Emit (PTE)
Additional Info Et Notes: Truck loading emissions controlled by ECD with DRE of 95%.
Truck loading emissions are only expected to occur during LACT unit downtime.
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: Contingency loading of condensate from storage tanks.
Company equipment Identification No. (optional): LOAD -1
For existing sources, operation began on:
N/A
For new or reconstructed sources, the projected start-up date is: 05/09/2019
Will this equipment be operated in any NAAQS nonattainment area?
Yes
0
No
El
Is this equipment located at a stationary source that is considered a Major Source of (HAP)
emissions?
Yes
No
•
p
Does this source load gasoline into transport vehicles?
Yes
No
■
p
Is this source located at an oil and gas exploration and production site?
Yes
No
GI
■
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual
average?
Yes
No
•
El
Does this source splash fill less than 6750 bbl of condensate per year?
Yes
No
■
p
Does this source submerge fill less than 16308 bbl of condensate per year?
Yes
No
■
PI
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019
21
AY COLORADO
Permit Number: AIRS ID Number:
[Leave blank, unless APED has already assigned a permit and AIRS ID]
Section 4 - Process Equipment Information
Product Loaded: p Condensate ❑ Crude Oil ❑ Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5:
118,084.80
bbl/year
Actual Volume Loaded:
This product is loaded from tanks at this facility into: Tank Trucks
(e.g. "rail tank cars" or "tank trucks")
98,402.00
bbl/year
If site specific emission factor is used to calculate emissions, complete the following:
Saturation Factor:
0.6
Average temperature of 66
bulk liquid loading:
True Vapor Pressure:
18.5
Psia®60'F
Molecular weight of 45 73
displaced vapors:
lb/lb-mol
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5:
N/A
bbl/year
Actual Volume Loaded:
N/A
bbl/year
Product Density:
N/A
lb/ft3
Load Line Volume:
N/A
ft3/truckload
Vapor Recovery Line Volume:
N/A
ft3/truckload
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019
�Y COLORADO
Permit Number:
AIRS ID Number:
/ /
[Leave blank unless APCD has already assigned a permit e and AIRS ID]
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.50068/-104.78163
�-
Operatot
Stack ID No
Discharge Height Above
Ground Level'.
(feet)
Temp
('F)
Flow.;Rate
-(ACF1)
Velocity .;
(ft/sec) -
LEED-1
25.58
1,076
97.2
0.15
Indicate the direction of the stack outlet: (check one)
✓❑ Upward
❑ Horizontal
❑ Downward
❑ Other (describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter (inches):
0 Other (describe):
❑ Upward with obstructing raincap
44
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.
❑ Loading occurs using a vapor balance system:
Requested Control Efficiency: %
❑ Combustion
Device:
Used for control of: VOCs and HAPs
Rating: 15.06
MMBtu/hr
Type: Enclosed Combuster Make/Model: Leed 48"
Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1,076 "F Waste Gas Heat Content: 2,582
Btu/scf
Constant Pilot Light: 0 Yes ❑ No Pilot Burner Rating: 0.058 MMBtu/hr
❑ Other:
Pollutants Controlled:
Description:
Requested Control Efficiency:
COLORADO
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit It and AIRS ID]
Section 7 - 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)
PM
SOx
NO.
CO
VOC
Enclosed Combuster
95%
HAPs
Enclosed Combuster
95%
Other:
❑ Using State Emission Factors (Required for GP07) VOC Benzene n -Hexane
D Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
O Crude 0.104 Lbs/BBL 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data?
2019
Criteria Pollutant Emissions Inventory
Pollutant
Emission Factor
Actual Annual Emissions
Requested Annual Permit
Emission Limit(s)5
Uncontrolled
Basis
Units
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions6
(tons/year)
Uncontrolled
Emissions
(tons/year)
Controlled
Emissions
(tons/year)
PM
N/A
N/A
N/A
N/A
N/A
N/A
N/A
SOx
N/A
N/A
N/A
N/A
N/A
N/A
N/A
NO.
0.068
lb/MMBtu
AP -42
N/A
0.02
N/A
0.04
CO
0.31
lb/MMBtu
AP -42
N/A
0.08
N/A
0.18
VOC
5.05E-01
Ibs/bbl
ProMax
24.84
1.24
29.81
1.49
Non -Criteria Reportable Pollutant Emissions Inventory
Chemical Name
Chemical
Abstract
Service (CAS)
Number
Emission Factor
Actual Annual Emissions
Uncontrolled
Basis
Units
i
Source
(AP -42,
Mfg., etc.)
Uncontrolled
Emissions
(pounds/year)
Controlled
Emissions 6
(pounds/year)
Benzene
71432
8.42E-04 lbs/bbl
ProMax
82.90
4.14
Toluene
108883
7.13E-04 lbs/bbl
ProMax
70.18
3.51
Ethylbenzene
100414
5.48E-05 lbs/bbl
ProMax
5.39
0.27
Xylene
1330207
2.36E-04 lbs/bbl
ProMax
23.26
1.16
n -Hexane
110543
8.46E-03 lbs/bbl
ProMax
832.72
41.64
2,2,4-
Trimethylpentane
540841
2.99E-05
lbs/bbl
ProMax
, 2.94
0.15
Other:
5 Requested values will become permit limitations. Requested limit(s) should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating, leave
blank.
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019
AV COLORADO
5 � '
Permit Number:
AIRS ID Number:
[Leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 8 - 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 GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Signature of Legally Authorized Person (not a vendor or consultant) Date
Brad Rogers
Health and Environmental Manager
Name (print) Title
Check the appropriate box to request a copy of the:
0 Draft permit prior to issuance
0 Draft permit prior to public notice
(Checking any of these boxes may result in an increased fee and/or processing time)
This emission notice is valid for five (5) years. Submission of a revised APEN is required 30 days prior to expiration
of the five-year term, or when a reportable change is made (significant emissions increase, increase production,
new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements.
Send this form along with $191.13 and the General Permit
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/aped
Form APCD-208 Hydrocarbon Liquid Loading APEN Revision 3/2019
6I AV
COLOR ADO
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