HomeMy WebLinkAbout20162163.tiff�V iC.IJLJ
COLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
11500 St
PO Box 758
Greeley, CO 80632
June 28, 2016
Dear Sir or Madam:
RECEIVED
JUN 3O2016
WELD COUNTY
COMMISSIONERS
On June 30. 2016, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Honebein 7G -203,323;7K -223,243,323,403;7O-243. A copy of this public notice and the
public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Regards,
Colorado Dept. of Public Health a Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: clara Gonzales
:*
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Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246.1530 P 303-692.2000 www.colorado.govrcdphe
John W. Hickenlooper, Governor Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
Cc- HL
711 /red
2016-2163
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Honebein 7G -203,323;7K -223,243,323,403;7O-243 - Weld County
Notice Period Begins: June 30, 2016
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: Honebein 7G -203,323;7K -223,243,323,403;7O-243
Oil and gas well production facility
NESW Section 7 T4N R64W
Weld County
The proposed project or activity is as follows: Applicant proposes to loadout condensate from condensate
storage tanks to tank trucks. Other permitted equipment at the facility are condensate storage tanks and a
compression engine, both authorized under general permits.
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, therDivision's analysis, and a draft of Construction Permit 16WE0676 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. Any such comment must be submitted in writing to the following addressee:
Andy Gruel
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-61
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
/�� COLORADO
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
DATE ISSUED:
ISSUED TO:
16WE0676
PDC Energy, Inc.
Issuance 1
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas facility, known as Honebein 7G -203,323;7K -223,243,323,403;7O-243,
located in the NESW of Section 7 of Township 4N Range 64W in Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
LOAD -1
001
Truck loadout of condensate. Emissions from the loadout are
not controlled.
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 THOSE GENERAL TERMS AND CONDITIONS
INCLUDED IN THIS DOCUMENT AND THE FOLLOWING SPECIFIC TERMS AND CONDITIONS:
REQUIREMENTS TO SELF -CERTIFY FOR FINAL AUTHORIZATION
1. This construction permit represents final permit approval and authority to operate this
emissions source. Therefore, it is not necessary to self -certify (Regulation 3, Part B,
Section III.G.5).
EMISSION LIMITATIONS AND RECORDS
2. Emissions of air pollutants shall not exceed the following limitations (as calculated in the
Division's preliminary analysis). (Reference: Regulation No. 3, Part B, Section II.A.4)
Annual Limits:
Facility
Equipment
ID
AIRS
Point
Tons per Year
Emission Type
VOC
LOAD -1
001
40.5
Point
See "Notes to Permit Holder" for information on emiss on factors and methods used to calculate
limits.
AIRS ID: 123/9E88/001
Page 1 of 7
Condensate Loadout TM Version 2012-1
Public Health and Environment
Air Pollution Control Division
Compliance with the annual limits shall be determined by recording the facility's annual
criteria pollutant emissions, (including all HAPs above the de-minimis reporting level)
from each emission unit, on a rolling twelve (12) month total. By the end of each month
a new twelve-month total shall be calculated based on the previous twelve months' data.
The permit holder shall calculate emissions each month and keep a compliance record
on site or at a local field office with site responsibility, for Division review. This rolling
twelve-month total shall apply to all permitted emission units, requiring an APEN, at this
facility.
PROCESS LIMITATIONS AND RECORDS
3. This source shall be limited to the following maximum processing rates as listed below.
Monthly records of the actual processing rate shall be maintained by the owner or
operator and made available to the Division for inspection upon request. (Reference:
Regulation 3, Part B, II.A.4)
Process/Consumption Limits
AIRS
Point
Process Parameter
Annual Limit
001
Condensate Loading
489,860 BBL
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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. Emission control devices subject to Regulation 7,
Sections XII.C.1.d or XVII.B.1.c shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
5. This source is located in an ozone non -attainment or attainment -maintenance area and
is subject to the Reasonably Available Control Technology (RACT) requirements of
Regulation Number 3, Part B, III.D.2.a. Condensate loading to truck tanks shall be
conducted by submerged fill. (Reference: Regulation 3, Part B, III.E)
6. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
7. The owner or operator shall follow loading procedures that minimize the leakage of
VOCs to the atmosphere including, but not limited to (Reference: Regulation 3, Part B,
III.D.2):
AIRS ID: 12319E881001 Page 2 of 7
p "TrPublic Health and Environment
Air Pollution Control Division
a. Hoses, couplings, and valves shall be maintained to prevent dripping, leaking,
or other liquid or vapor loss during loading and unloading.
b. All compartment hatches at the facility (including thief hatches) shall be closed
and latched at all times when loading operations are not active, except for
periods of maintenance, gauging, or safety of personnel and equipment.
c. The owner or operator shall inspect onsite loading equipment during loading
operations to monitor compliance with above conditions. The inspections shall
occur at least monthly. Each inspection shall be documented in a log available
to the Division on request.
8. All hydrocarbon liquid loading operations, regardless of size, shall be designed, operated
and maintained so as to minimize leakage of volatile organic compounds to the
atmosphere to the maximum extent practicable.
OPERATING & MAINTENANCE REQUIREMENTS
9. This source is not required to follow a Division -approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
10. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
11. A revised Air Pollutant Emission Notice (APEN) shall be filed: (Reference: Regulation
No. 3, Part A, II.C)
a. 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 (NO„) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOx per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
AIRS ID: 12319E881001 Page 3 of 7
d. Whenever a permit limitation must be modified; or
Public Health and Environment
Air Pollution Control Division
e. No later than 30 days before the existing APEN expires.
12. Federal regulatory program requirements (i.e. PSD, NANSR) shall apply to this source at
any such time that this source becomes major solely by virtue of a relaxation in any
permit condition. Any relaxation that increases the potential to emit above the applicable
Federal program threshold will require a full review of the source as though construction
had not yet commenced on the source. The source shall not exceed the Federal
program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
13. 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 No. 3, Part B, Section II.B upon a request for transfer of ownership
and the submittal of a revised APEN and the required fee.
14. 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 No. 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.
15. 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.
16. 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.
17. Each and every condition of this permit is a material part hereof and is not severable.
Any challenge to or appeal of a condition hereof shall constitute a rejection of the entire
permit and upon such occurrence, this permit shall be deemed denied ab initio. This
permit may be revoked at any time prior to self -certification and final authorization by the
Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality
Control Act and regulations of the Air Quality Control Commission (AQCC), including
failure to meet any express term or condition of the permit. If the Division denies a
permit, conditions imposed upon a permit are contested by the owner or operator, or the
Division revokes a permit, the owner or operator of a source may request a hearing
before the AQCC for review of the Division's action.
AIRS ID: 123/9E881001 Page 4 of 7
fuel" of Public Health and Environment
Air Pollution Control Division
18. 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.
19. 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:
Andy Gruel, P.E.
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc. New synthetic minor facility.
Issued directly to Final Approval.
AIRS ID: 12319E881001 Page 5 of 7
Public Health and Environment
Air Pollution Control Division
Notes to Permit Holder at the time of this permit issuance:
1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these
fees will be issued after the permit is issued. The permit holder shall pay the invoice within 30 days of
receipt of the invoice. Failure to pay the invoice will result in revocation of this permit (Reference:
Regulation No. 3, Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are
based on the consumption rates requested in the permit application. These limits may be revised
upon request of the owner or operator providing there is no exceedance of any specific emission
control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN)
and complete application form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions. The owner or operator shall notify the Division
of any malfunction condition which causes a violation of any emission limit or limits stated in this
permit as soon as possible, but no later than noon of the next working day, followed by written notice
to the Division addressing all of the criteria set forth in Part II.E.1. of the Common Provisions
Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-reqs
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
Emission
Rate
(lb/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
001
Benzene
71432
270
Yes
N/A
Toluene
108883
401
Yes
N/A
n -Hexane
110543
2173
Yes
N/A
5) The emission levels contained in this permit are based on the following emission factors:
CAS
Pollutant
Emission Factors
Ib/BBL loaded
- Uncontrolled
Source
VOC
0.1653
AP -42
71432
Benzene
0.00055
Enq. Calc
108883
Toluene
0.00082
Eng. Calc
110543
n -Hexane
0.00444
Eng. Calc
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) = 5.105 psia [modeled by Promax]
M (vapor molecular weight) = 53.261 Ib/Ib-mol [modeled by Promax]
T (temperature of liquid loaded) = 516.131 °R [modeled by Promax]
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP as modeled by Promax by the VOC emission factor,
and then dividing by the mass fraction of VOC as modeled by Promax.
AIRS ID: 123/9E88/001
Page 6 of 7
of ;;ado
JUL
6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with
this permit is valid for a term of five years from the date it was received by the Division. A revised
APEN shall be submitted no later than 30 days before the five-year term expires. Please refer to the
most recent annual fee invoice to determine the APEN expiration date for each emissions point
associated with this permit. For any questions regarding a specific expiration date call the Division at
(303)-692-3150.
7) This facility is classified as follows:
ihe
of Public Health and Environment
Air Pollution Control Division
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of: VOC
NANSR
Synthetic Minor Source of: VOC
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be
found at the website listed below:
http://ecfr.gpoaccess.gov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A — Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A — Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
I Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
AIRS ID: 123/9E881001 Page 7 of 7
Division Information
Engineer
Andy Gruel
Control Engineer
Stefanie Rucker
Review Date.
06/22/2016
Application Date.
05/18/2016
Facility Identifiers
Permit No.
16WE0676
AIRS
Coun #
Facility#
1 eld
9E88
Point#
001
Section 01: Administrative Information
Company Name'
PDC Energy, Inc.
Source Name:
Honebein 7G -203.323-.7K-223.243,323.403.70-243
Source Location
NESW Section 7 T4N R64W (non -attainment)
South of Kersey
SIC:
1311
Elevation (feet)
484E
Portable Source?
Portable Source Homebase
Mailing
Address
Address 1
Address 2
City. State Zip
PDC Energy, Inc.
1775 Sherman Street, Suite 3000
Denver. CO 80203
Person To
Contact
Name.
Phone.
Fax
Email:
Elizabeth Duncan
303-860-5800
303-860-5838
elizabethduncan(pdce. corn
Section 02 - Emissions Inventory Analysis
AP -42: Chapter 5.2
Equation 1
L = 12 46"S"P"M/T
L = loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P = true vapor pressure of liquid loaded [psial
M = molecular weight of vapors Illo/lb-rnolet
T = temperature of bulk liquid loaded [deg. R)
1 degree Fahrenheit = 460.67 degree Rankine
Criteria Pollutants
Variables
S
P
M
T
L
06 Submerged loadingdedicated normal service
5.105 psia modeled by ProMax based on site -specific
53.261 lb/lb-mole pressurized gas sample taken 5/10/16
516-131 deg. R
3.938
1.65E -0t
lb/10^3 gal
lb/bbl
Annual requested Throughput
Annual requested VOC emissions
White values with black background are
20,574,120 Gallons per Year
Pounds per Year
4 .5 Tons VOC per Year
Non -Criteria Reportable Air Pollutants/Hazardous Air Pollutants
VOC Mass Mass Ratio
NCRP Mass Fraction (pounds Are
Fraction (Promax (Promax HAP/pound Emissions Emissions
Component model) model) VOC) lb r Reportable?
Benzene 0.00222012 06657548 0.0033 270 Yes
Toluene 0.0032907 0.6657548 0.0049 401 Yes
n -hexane 0.0178529 0.6657548 0.0268 2,173 Yes
NCRP emissions were calculated by multiplying the VOC emission factor
calculated above by the mass ratio of the NCRP (based on Promax model of condensate flash
emissions composition) and dividing that by the mass ratio of VOC from the Promax model.
NCRP EF (lb/bbl) = VOC EF (lb/bbl) NCRP mass frac (lb NCRP/Ib gas) / VOC mass frac (lb VOC/lb gas)
Section 03 - Regulatory Considerations
Is this site considered an exploration and production location (e.g. well pad)? Yes
If yes, review the following two exemptions for applicability:
Does the operator unload less than 10,000 gallons (238 BBLs) of crude oil per day on an annual average basis? No
If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1
Does this operator unload less than 6,750 bbls per year of condensate via splash fill or
16,308 bbls per year of condensate via submerged fill procedure? No
If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section 11.0.1.1
Is this site located in an ozone non -attainment area? Yes
If yes, this source is subject to Reasonably Available Control Technology (RACT) requirements under Regulation 3, Part B
Section III.D.2.a. This requirement may be met using "submerged fill" and/or vapor balance with emissions routed to an
emissions control device.
Is this facility classified as a major source of HAPs? No
If yes, evaluate if 40 CFR, Part 63, Subpart EEEE "Organic Liquids Distribution" MACT provisions apply
Does this facility involve the loading of refined crude/condensate in the form of "gasoline"?
If yes, proceed to evaluate the following:
Is this facility classified as a "Terminal" as defined per Regulation 7, Section VI.C.2.a?
If yes, the provisions of Regulation 7, Section VI.C.2 may apply
No
No
Is this facility classified as a "Bulk Plant" as defined per Regulation 7, Section VI.C.3.a? No
If yes, the provisions of Regulation 7, Section VI.C.3 may apply
Section 04 - SCC Coding
Emissions Factor
Pollutant (lb/1,000 gallons)
VOC 3.938 b/1,000 gallons
Benzene O0131 b/1,000 gallons
Toluene 0.0195 b/1,000 gallons
n -hexane 0.1056 b/1,000 gallons
40600132: Crude Oil: Submerged Loading (Normal Service) Use d S = 0.6
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Section 07 — Control Device Information
Section 08 — Emissions Inventory Information
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Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
Requested Permitted
Emissions
Controlled
(Tons/Year)
a)
269.95 lb/yr
2170.81 lb/yr
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Uncontrolled
(Tons/Year)
40.49
269.95 lb/yr
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(Tons/Year)
269.95 lb/yr
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(Tons/Year)
40.49
269.95 lb/yr
2170.81 lb/yr
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Control Device Description
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(See reverse side for guidance on completing this form)
AIRS ID Number: TBD
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Permit Number:
PDC Energy, Inc.
Company Name:
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Honebein 7G-203, 323; 7K-223, 243, 323, 403; 7O-243
Plant Location:
Elizabeth Duncan
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Fax Number:
Elizabeth.Duncan@pdce.com
E-mail Address:
Controlled Actual
Emissions
(lbs/year)
400.13lb/yr
Uncontrolled
Actual Emissions
(lbs/year)
400.13 lb/yr
Emission Factor
Source
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Emission Factor
(Include Units)
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Control Equipment
/ Reduction (%)
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Chemical Abstract 7 --
Service (CAS) Chemical Name
Number
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EHS Professional
Elizabeth Duncan
Title of Person Legally Authorized to Supply Data
Name of Person Legally Authorized to Supply Data (Please print)
05-4.
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