HomeMy WebLinkAbout20163706.tiffCOLORADO
Department of Public
Health & Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
November 29, 2016
Dear Sir or Madam:
RECEIVED
DEC 0 5 2016
WELD COUNTY
COMMISSIONERS
On December 1, 2016, the Air Pollution Control Division will begin a 30 -day public notice period for
PDC Energy, Inc. - Wiedeman Trust Federal Sec 29 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 Et Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
RibLIG
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
John W. Hickentooper, Governor Larry Wotk, MD, MSPH, Executive Director and Chief Medical Officer
c,c.'• Cwt-Ctrntn!TP), HLCf )
pWCE,t(C tISm/cts)
2016-3706
i/Co/ICo
Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc. - Wiedeman Trust Federal Sec 29 Pad - Weld County
Notice Period Begins: December 1, 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: Wiedeman Trust Federal Sec 29 Pad
Oil Et Gas Exploration and Production Facility
SENW Section 29 T4N R66W, near Gilcrest
Weld County
The proposed project or activity is as follows: Applicant requests an individual construction permit for
loadout at a new EaP site. Other equipment at this facility are condensate and produced water storage
tanks.
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):
• 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 16WE1085 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-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
COLORADO
Colorado Air Permitting Project
Version No. 1.00
Project Details
Review Engineer:
Package #:
Received Date:
Review Start Date:
Section 01- Facility Information
Andy Gruel
354118
10/3/2016
11/23/2016
Company Name:
County AIRS ID:
Plant AIRS ID:
Facility Name: Wiedeman Trust Federal Sec 29 Pad
Physical Address/Location: SENW Section 29 T4N R66W
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
❑ Particulate Matter (PM)
PDC Energy, Inc.
123
9EE9
If yes, for what pollutant? ❑ Carbon Monoxide (CO)
Section 02 - Emissions Units In Permit Application
❑ Ozone (NOx & VOC)
AIRS Point #
Emissions Source Type
Emissions
Control?
Permit #
Issuance #
Self Cert
Required?
Action
Engineering Remarks
001
Hydrocarbon Liquid Loading .
No
16WE1085
1
No
Permit initial
Issuance
Section 03 - Description of Project
Applicant requests an individual permit for condensate loadout at a new E&P site. Uncontrolled VOC emission are less than 10 tpy, so the new policy
of requiring a RACT analysis for control is not applicable to this application. Issued directly to Final Approval.
Section 04 - Public Comment Requirments
Is Public Comment Required? Yes
If yes, why?" Requesting Synthetic Minor Pere
Section 05 - Ambient Air Impact Analysis Requirements
Was a quantitative modeling analysis required?2 Rica
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, explain what programs and which pollutants here:
Title V Operating Permits (OP) : VOC
Non -Attainment New Source Review (NANSR): VOC
Is this stationary source a major source?
If yes, explain what programs and which pollutants here:
No
Yes
001 Hydrocarbon Loadout to Tanker Trucks
123-9EE9-001 16WE1085 CP1 APEN rec'd 10/3/16
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 Table 5.2-1: Submerged loading
P
True Vapor Pressure
5.63
psia
M
Molecular Weight of Var
53.57
lb/lb-mole
T
Liquid Temperature
516.461
deg. R
Field Data
L
Annual requested Throughput
Annual requested VOC emissions
Control:
Efficiency:
No Control
4.364 lb/10^3 gal
0.1833 lb/bbl
0.00%
95662 BBL/yr
4017804 gal/yr
17535 lb/yr
8.77 tpy
NCRPs
NCRP Emission Factors are calculated by multiplying the VOC emission factor calculated above
by the NCRP mass fraction in the vapor, and dividing by the mass fraction of VOC in the vapor.
NCRP Emission Factor
(lb/bbl)
Component
NCRP Mass Fraction
VOC Mass Fraction
Benzene
0.0028069
0.70693331
0.00072779
Toluene
0.0042535
0.70693331
0.00110290
Ethylbenzene
0.0000861
0.70693331
0.00002233
Xylenes
0.0013440
0.70693331
0.00034850
n -Hexane
0.0208747
0.70693331
0.00541260
2,2,4-TMP
0.0001338
0.70693331
0.00003469
Source:
Promax model of condensate flash emission vapors
Emissions Summary Table
Pollutant
Emission Factor
Uncontrolled Emissions
Controlled Emissions
Source
VOC
0.1833
lb/bbl
8.77 tpy
8.77 tpy
AP -42
Benzene
0.0007
lb/bbl
69.62 lb/yr
69.62 lb/yr
Mass
Balance
Toluene
0.0011
lb/bbl
105.51 lb/yr
105.51 lb/yr
Mass
Balance
Ethylbenzene
0.000022
lb/bbl
2.14 lb/yr
2.14 lb/yr
Mass
Balance
Xylene
0.0003
lb/bbl
33.34 lb/yr
33.34 lb/yr
Mass
Balance
n -Hexane
0.0054
lb/bbl
517.78 lb/yr
517.78 lb/yr
Mass
Balance
2,2,4-TMP
0.000035
Ib/bbl
3.32 lb/yr
3.32 lb/yr
Mass
Balance
1123-9EE9-001 16WE1085 Cp1
Regulatory Review
Regulation 1 - Particulate. Smoke, Carbon Monoxide and Sulfur Dioxide
Section II.A.1 - Except as provided in paragraphs 2 through 6 below, no owner or operator of a source shall allow
or cause the emission into the atmosphere of any air pollutant which is in excess of 20% opacity. This standard is
based on 24 consecutive opacity readings taken at 15 -second intervals for six minutes. The approved reference
test method for visible emissions measurement is EPA Method 9 (40 CFR, Part 60, Appendix A (July, 1992)) in all
subsections of Section II. A and B of this regulation.
Section II.A.5 - Smokeless Flare or Flares for the Combustion of Waste Gases No owner or operator of a
smokeless flare or other flare for the combustion of waste gases shall allow or cause emissions into the
atmosphere of any air pollutant which is in excess of 30% opacity for a period or periods aggregating more than six
minutes in any sixty consecutive minutes.
Regulation 2 — Odor
Section I.A - No person, wherever located, shall cause or allow the emission of odorous air contaminants from any
single source such as to result in detectable odors which are measured in excess of the following limits: For areas
used predominantly for residential or commercial purposes it is a violation if odors are detected after the odorous
air has been diluted with seven (7) or more volumes of odor free air.
Regulation) 3 - APEN and Permitting Requirements
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) 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 II.D.1.I
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.I
N/A
No
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for: each individual emission
point in a non -attainment area with uncontrolled actual emissions of one ton per year or more of any individual
criteria pollutant (pollutants are not summed) for which the area is non -attainment.
(Applicant is required to file an APEN since emissions exceed 1 ton per year VOC)
Part B — Construction Permit Exemptions
Applicant is required to obtain a permit since uncontrolled VOC emissions from this facility are greater than
the 2.0 TPY threshold (Reg. 3, Part B, Section II.D.2.a).
Part B, III.D.2 - RACT requirements for new or modified minor sources
This section of Regulation 3 requires RACT for new or modified minor sources located in nonattainment or
attainment/maintenance areas. This source is located in the 8 -hour ozone nonattainment area, but not the 1 -hour
ozone area.
The date of interest for determining whether the source is new or modified is therefore November 20, 2007 (the
date of the 8 -hour ozone NA area designation). Since the tank battery from which loadout is occurring came into
service after the date above (Reported as 07/02/14 on condensate tank APEN), this source is considered "new or
modified." Operator is using submerged fill (0.6 saturation factor), therefore, RACT requirements are
satisfied.
Regulation 7 --Volatile Organic Compounds
No sections apply. Per Regulation 7, Section VI.C, a terminal is defined as a petroleum liquid storage and
distribution facility that has a daily average throughput of more than 76,000 liters of gasoline (20,000 gallons),
which is loaded directly into transport vehicles.
This facility is neither a terminal, nor a bulk plant per definitions in Reg 7, Section VI.C.
Regulation 8 — Hazardous Air Pollutants
MACT EEEE:
Not subject because facility is true minor source of HAPs
It should also be noted that the loadout operation is located at a production field facility and thus would be exempt
per 40CFR 63.2334(c)(1).
SCC CODING
Uncontrolled Emissions Factor
Pollutant (lb/1,000 gallons)
VOC 4.3643 lb/1,000 gallons 0.0%
Benzene 0.0173 lb/1,000 gallons 0.0%
n -hexane 0.1289 lb/1,000 gallons 0.0%
Control Efficiency
40600132: Crude Oil: Submerged Loading (Normal Service) Use if S = 0.6
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
FACILITY EMISSION SUMMARY
Company Name
County AIRS ID
Plant AIRS ID
Facility Name
PDC Energy, Inc.
123
9EE9
Wledeman Trust Federal Sec 29 Pad
History File Edit Date
11/23/2016
Oxon Status
Non -Attainment
EMISSIONS - Uncontrolled (tons per year
EMISSIONS With Controls (tons per year
POINT
AIRS
ID
PERMIT
Description
PM10
PM2.S
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
PM10
PM2.5
H2S
SO2
NOx
VOC
Fug
VOC
CO
Total
HAPs
REMARKS
Previous FACILITY TOTAL
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
New Facility - No Previous Total
Previous Permitted Facility total
0.0
0.0
0.0
0.0
0.0
O 0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
001
16WE1085
Loadout
8.8
0.4
8.8
0.4
New point
002
GP01
Condensate storage. 3228 bbl
0.5
118.5
1.0
3.2
0.5
5.9
1.0
0.2
SSEFs accepted
003
GP08
Produced water storage 1210 bbl
2.4
0.3
2.4
0.3
Detautt EFs
APEN-E empt / Insignifica
ts'.
XA
External Combustion Sources
0.1
0.1
1.1
0.0
0.9
0.0
0.1
0.1
1.1
0.0
0.9
0.0
XA
Fugitives
0.1
0.0
0.1
0.0
FACILITY TOTAL
0.1
0.1
0.0
0.0
1.8
129.7
0.1
1.9
3.9
0.1
0.1
0.0
0.0
1.8
17.1
0.1
9.9
0.8
VOC: Syn Minor (NANSR and OP)
NOx: Minor (NANSR and OP)
CO: Minor (PSD and OP)
HAPS: Minor
WI: Minor • affected Area
ZZZZ: Minor
Permitted Facility Total
0.0
0.0
0.0
0.0
0.5
129.7
0.0
1.0
3.9
0.0
0.0
0.0
0.0
0.5
17.1
0.0
1.0
as
Excludes units exempt earn perrnfs/APENs
(O) Change in Permitted Emissions
0.0
0.0
0.0
0.0
0.5
17.1
0.0
1.0
Pubcom required because of new synthetic minor
permit
Note 1
Total VOC Facility Emissions (point and fugitive)
(A) Change in Total Permitted VOC emissions (point and fugitive)17.1
17.2
Facility is eligible for GP02 because < 90 tpy
Project emissions less Man 25/50 tpy
Note 2
Page I of2
Printed 11/23/2016
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION DIVISION
FACILITY EMISSION SUMMARY - HAPs
Company Name PDC Energy, Inc.
County AIRS ID 123
Plant AIRS ID 9EE9
Facility Name Wiedeman Trust Federal Sec 29 Pad
POINT PERMIT Description
Formaldehyde
-
Acetaldehyde
.... t.....
Acrolein
r._. 7__.J
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
16WE1085
Loadout
70
106
2
34
518
3
0.4
002
GP01
Condensate storage, 3228 bbl
765
5697
32
003
GP08
Produced water storage, 1210 bbl
128
402
0.3
APEN-Exempt
/ Insignificants:
XA
External Combustion Sources
0.0
XA
Fugitives
3
3
3
3
4
0.0
TOTALftpy)
0.0
0.0
0.0
0.5
0.1
0.0
0.0
3.3
0.0
0.0
0.0
0.0
3.9
'Total Reportable = all HAPs where uncontrolled emissions > de minimus values
Red Text uncontrolled emissions < de minimus
POINT PERMIT Description
Formaldehyde
Acetaldehyde
Acrolein
Benzene
Toluene
Ethylbenzene
Xylenes
n -Hexane
McOH
224 TMP
H2S
TOTAL (tpy)
Previous FACILITY TOTAL
0
0
0
0
0
0
0
0
0
0
0
0
0.0
001
16WE1085
Loadout
70
106
2
34
518
3
0.4
002
GP01
Condensate storage, 3228 bbl
39
285
02
003
GP08
Produced water storage, 1210 bbl
128
402
0.3
APEN-Exempt
/ Insignificants:
XA
External Combustion Sources
0.0
XA
Fugitives
3
3
3
3
4
0.0
TOTALI(tpy)
0.0
0.0
0.0
0.1
0.1
0.0
0.0
0.6
0.0
0.0
0.0
0.0
0.8
2
1239EE9.xlsx
11/23/2016
STATE OF COLORADO
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150
CONSTRUCTION PERMIT
PERMIT NO:
16WE1085
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 facility, known as the Wiedeman Trust Federal Sec 29 Pad, located in the
SENW of Section 29 of Township 4N Range 66W, 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
8.8
Point
See "Notes to Permit Holder" for information on emission factors and methods used to calculate
limits.
AIRS ID: 123/9EE9
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
95,662 bbl
The owner or operator shall calculate monthly process rates based on the calendar
month.
Compliance with the annual throughput limits shall be determined on a rolling twelve (12)
month total. By the end of each month a new twelve-month total is calculated based on
the previous twelve months' data. The permit holder shall calculate throughput each
month and keep a compliance record on site or at a local field office with site
responsibility, for Division review.
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.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)
AIRS ID: 123/9EE9 Page 2 of 7
Public Health and Environment
Air Pollution Control Division
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):
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 (NOX) in
ozone nonattainment areas emitting less than 100 tons of VOC 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.
AIRS ID: 123/9EE9 Page 3 of 7
Public Health and Environment
Air Pollution Control 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
d. Whenever a permit limitation must be modified; or
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
AIRS ID: 123/9EE9 Page 4 of 7
Public Health and Environment
Air Pollution Control Division
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,
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. Issued as Final
Approval.
AIRS ID: 123/9EE9 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-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
Emission
Rate
(Ib/yr)
Are the
emissions
reportable?
Controlled
Emission
Rate (Ib/yr)
001
Benzene
71432
70
No
N/A
Toluene
108883
106
No
N/A
Ethylbenzene
100414
2
No
N/A
Xylenes
1330207
33
No
N/A
n -Hexane
110543
518
Yes
N/A
2,2,4-
Trimethylpentane
540841
3
No
N/A
5) The emission levels contained in this permit are based on the following emission factors:
CAS
Pollutant
Emission Factors
Uncontrolled
lb/BBL loaded
-
Source
VOC
0.1833
AP -42
71432
Benzene
0.0007
Eng. Calc.
110543
n -Hexane
0.0054
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) = 5.63 psia
M (vapor molecular weight) = 53.57 Ib/Ib-mol
T (temperature of liquid loaded) = 516.461 °R
AIRS ID: 123/9EE9
Page 6 of 7
Public Health and Environment
Air Pollution Control Division
The uncontrolled non -criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors (as modeled by Promax), by the VOC
emission factor, and then dividing by the mass fraction of VOC in the vapors (as modeled by
Promax.
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:
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
Subpart QQQ — Subpart YYYY
MACT
63.6580-63.8830
Subpart ZZZZ - Subpart MMMMM
MACT
63.8980 -End
Subpart NNNNN — Subpart XXXXXX
AIRS ID: 123/9EE9
Page 7 of 7
CC
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Section 02 — Re
Section 01 — Administrative Information
General Permit GP07
Individual Permit
PDC Energy, Inc.
Company Name:
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Please use the APCD Non -Criteria Reportable Air Pollutant Addendum form to report pollutants not listed above.
Requested Permitted
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(Tons/Year)
8.77
69.62 lb/yr (DM)
517.78 lb/yr
Uncontrolled
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8.77
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