HomeMy WebLinkAbout20162696.tiffCOLORADO
Department of Public
Health Er Environment
AUG 1 8 ?O;;3
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
August 15, 2016
Dear Sir or Madam:
On August 18, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for PDC
Energy, Inc. - Collins 18Q-221, 301; 18T-201, 221, 321, 341. A copy of this public notice and the
public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
I
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickenlooper, Governor • Larry Wolk, MD, MSPH, Executive Director and Chief Medical Officer
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2016-2696
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Collins 18Q-221, 301; 18T-201, 221, 321, 341 - Weld County
Notice Period Begins: August 18, 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: Collins 18Q-221, 301; 18T-201, 221, 321, 341
Exploration and Production well pad
SESE Sec. 18 T4N R64W
Weld County
The proposed project or activity is as follows: New exploration and production facility for the production of
condensate. Natural gas from the wellhead separators is compressed and routed into a sales pipeline.
Condensate is routed to twelve 400 -bbl condensate storage tanks. Tank vapors are controlled by enclosed
combustors. Produced water is sent to produced water storage tanks. Tank truck loading is conducted by
submerged fill; emissions from loadout are not controlled.
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 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 16WE0745 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:
Betsy Gillard
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
.647COL OF..DA
DRAFT STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO: 16WE0745
Issuance 1
DATE ISSUED:
ISSUED TO: PDC Energy, Inc.
THE SOURCE TO WHICH THIS PERMIT APPLIES IS DESCRIBED AND LOCATED AS FOLLOWS:
Oil and gas exploration and production facility known as the Collins 18Q-221, 301; 18T-
201, 221, 321, 341 Pad, located in the SESE Sect. 18 T4N, R64W, Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility
Equipment
ID
AIRS
Point
Description
LOAD -1
003
Hydrocarbon Loadout to Tanker Trucks. Emissions are
uncontrolled.
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
NO x
VOC
CO
LOAD -1
003
--
39.5
--
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
AIRS ID: 12319E92
Page 1 of 7
Colorado De
artment of Public Health and Environment
r� T� Air Pollution Control Division
Compliance with thal 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 rates 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
Facility
Equipment
ID
AIRS
Point
Process Parameter
Annual Limit
LOAD -1
003
Condensate Loaded
by Submerged Fill
357,910 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
4. 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.2.b shall have no visible emissions. (Reference: Regulation
No. 1, Section II.A.1. & 4.)
5. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
6. 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)
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.E):
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 (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.
AIRS ID: 123/9E92 Page 2 of 7
Colorado De.artment of Public Health and Environment
Air Pollution Control Division
c. The owner . +. at. pe :..' g e..'.ment and operations on site at
the time of the inspection to ensure compliance with the conditions (a) and (b)
above. 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
Initial Testing Requirements
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)
d. 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 V0C or NO, per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non -criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
Whenever there is a change in the owner or operator of any facility, process, or
activity; or
Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
g. Whenever a permit limitation must be modified; or
h. No later than 30 days before the existing APEN expires.
e.
12. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
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
AIRS ID: 123/9E92 Page 3 of 7
Colorado De•artment of Public Health and Environment
Air Pollution Control Division
to emit above the 4Ai2bl d - •ro• reshdh-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.
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,
AIRS ID: 123/9E92 Page 4 of 7
Colorado Department of Public Health and Environment
Air Pollution Control Division
civil or criminal erwL eRer( unLectiotL25-7-115 (enforcement), -121
(injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S.
By:
Betsy Gillard
Permit Engineer
Permit Histo
Issuance
Date
Description
Issuance 1
This Issuance
Issued to PDC Energy, Inc.
AIRS ID: 12319E92 Page 5 of 7
Colorado De ailment of Public Health and Environment
D It_L\L_
IT1 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: http://www.colorado.gov/cs/Satellite?c=Document C&childoagename=CDPHE-
Main%2FDOcument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
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
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission Rate
(Ibtyr)
003
Benzene
71432
201
No
N/A
n -Hexane
110543
1620
Yes
N/A
Toluene
108883
279
Yes
N/A
5) The emission levels contained in this permit are based on the following emission factors:
Point 003:
Pollutant
Emission
lb/BBL loaded
Factors - Uncontrolled
Source
VOC
0.2210
AP -42
Benzene
0.0006
AP -42
n -Hexane
0.0045
AP -42
Toluene
0.0008
AP -42
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) = 6.93 psia
M (vapor molecular weight) = 52.49 Ib/Ib-mol
AIRS ID: 123/9E92
Page 6 of 7
T (temperatu uid -',e5- 1
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:
Colorado De artment of Public Health and Environment
TAir Pollution Control Division
Applicable
Requirement
Status
Operating Permit
Synthetic Minor Source of:
VOC
NANSR
Synthetic Minor Source of:
VOC
MACT HH
Major Source Requirements: Not Applicable
Area Source Requirements: Not Applicable
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.qpoaccess.qov/
Part 60: Standards of Performance for New Stationary Sources
NSPS
60.1 -End
Subpart A— Subpart KKKK
NSPS
Part 60, Appendixes
Appendix A —Appendix I
Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories
MACT
63.1-63.599
Subpart A — Subpart Z
MACT
63.600-63.1199
Subpart AA — Subpart DDD
MACT
63.1200-63.1439
Subpart EEE — Subpart PPP
MACT
63.1440-63.6175
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ — Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
AIRS ID: 123/9E92
Page 7 of 7
Division Information
Engineer:
Betsy Gillard
Control Engineer:
Stefanie Rucker
Review Date:
08/09/2016
Application Date:
06/06/2016
Facility Identifiers
Permit No.
16WE0745
AIRS
County #
123 (Weld
Facility #
9E92
Facility Type:
exploration and production facility
El Located In the 8 -hour non -attainment area?
Administrative Information
Company Name:
PDC Energy, Inc.
Source Name:
Collins 18Q-221, 301; 18T-201, 221, 321, 341
Source Location:
SIC:
SESE Sec. 18 T4N R64W
1311
Mailing
Address
Address 1:
Address 2:
ty, 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
Elizabeth.Duncan@pdce.com
O True Minor
@ Synthetic Minor for:
r VOC f` Nox CO
Requested Action
Self Certification Required?
Issuance Number:
No
1
Source Description:
Oil and gas exploration and production facility known as the Collins 18Q-221, 301; 18T-201, 221, 321, 341, located in
the SESE Sec. 18 T4N R64W, Weld County, Colorado.
Point
Name
Type
Control
Action
003
LOAD -1
Loadout
None
Newly
reported
source
003 Hydrocarbon Loadout to Tanker Trucks
Calculations
L = 12.46*S*P*M/T (AP -42: Chapter 5.2, Equation 1)
L = loading losses in lb per 1000 gallons loaded
Factor
Meaning
Value
Units
Source
S
Saturation Factor
0.6
AP -42
P
True Vapor Pressure
6.9282
psia
ProMax
M
Molecular Weight of Vap
52.458
lb/lb-mole
ProMax
T
Liquid Temperature
516.46
deg. R
ProMax
L
5.26 lb/10^3 gal
2.21E-01 lb/bbl
Annual requested Throughput
Annual requested VOC emissions
Control: None
Efficiency: 0.00%
NCRPs
Component
Benzene
0.0021
n -hexane
0.0173
Toluene
0.0019
Xylenes
0.0005
Source:
Mass Fraction
ProMax
Emissions Summary Table
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
0.2210
lb/bbl
39.5 tpy
39.5 tpy
AP -42
Benzene
0.0006
lb/bbl
214.7 lb/yr
214.7 lb/yr
AP -42
n -Hexane
0.0045
lb/bbl
1611 lb/yr
1610.6 lb/yr
AP -42
Toluene
0.0008
lb/bbl
286 lb/yr
286.3 lb/yr
AP -42
357910 BBL/yr
15032220 gal/yr
79084 lb/yr
39.54 tpy
Minor discrepancies between permitted emissions and PA
calculations are a result of rounding errors. Permit reflects
operator requested permitted emissions.
Regulatory Review
Regulation 3 - APEN and Permitting Requirements
Is this site considered an exploration and production location (e.g. well pad)?
If yes, review the following two exemptions for applicability:
Does the operator unload less than 10,000 gallons (238 BBLs) per day of crude oil on an annual average basis?
If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section 11.0.1.1
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?
If yes, this emissions point is categorically exempt from permit requirements per Regulation 3, Part B, Section II.D.1.1
No
Yes
No
:J
C
equested Action (Check applicable request boxes)
N
Section 01 — Administrative Information
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1775 Sherman Street, Suite 3000
Mailing Address
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Elizabeth Duncan
(303) 860-5838
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ie Number: (303) 860-5800
Initial application for new facility
Addl. Info. & Notes:
General Information
Normal Hours of Source Operation:
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Section 07 —Control Device Information
Section 08 — Emissions Inventory Information
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Data year for actual calendar year emissions below & throughput in Sec. 04 (e.g. 2007):
Emission Factor Documentation attached (If using site specific emission factor)
Estimation
Method or
Emission
Factor Source
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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)
39.54
0
1620.11 lb/yr
0
201.18 lb/yr (DM)
T
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Actual Calendar Year Emissions5
Controlled
(Tons/Year)
39.54
0
1620.11 lb/yr
T
0
0
Uncontrolled
(Tons/Year)
In
201.18 lb/yr (DM)
'1620.11 lb/yr
(c)
a
25
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Controlled Actual
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279.01
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279.01
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