HomeMy WebLinkAbout20143826.tiff A CDPHE COLORADO
CO ADepartment of Public
.- Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Weld County - Clerk to the Board RECEIVED
1150 0 St
PO Box 758
Greeley, CO 80632 DEC 1 0 2014
December 8, 2014 WE• COMMISSIONERS
LD � Y
Dear Sir or Madam:
On December 10, 2014, the Air Pollution Control Division will begin a 30-day public notice period for
PDC Energy, Inc - Richter 34R-223, 403, 423; 34U-303/Richter 34M-203, 423; 34R-343. 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 8 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
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4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe �e� . 0,,
-John W. Hickenlooper, Governor I Larry Wolk,MD,MSPH, Executive Director and Chief Medical Officer l
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2014-3826
CDPHE Air Pollution Control Division
CO s Notice of a Proposed Project or Activity Warranting Public
Comment
Website Title: PDC Energy, Inc - Richter 34R-223, 403, 423; 34U-303/Richter 34M-203, 423; 34R-343 - Weld
County
Notice Period Begins: December 10, 2014
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: Richter 34R-223, 403, 423; 34U-303/Richter 34M-203, 423; 34R-343
Oil and gas exploration and production facility
SESE Section 27, T7N, R34W
Weld County
The proposed project or activity is as follows: Oil and gas exploration and production facility including truck
loadout and condensate 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):
• 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 Permits 14WE1221 and
14WE1226 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:
Stephanie Chaousy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
1 I ®+Y g COLORADO
111
STATE OF COLORADO
oF'Cow
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT a4,
AIR POLLUTION CONTROL DIVISION °'
TELEPHONE: (303)692-3150
\fine/
CONSTRUCTION PERMIT
PERMIT NO: 14WE1221
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 Richter 34R-223, 403, 423; 34U-303/Richter 34M-203, 423;
34R-343, located in the SESE of Section 27, Township 7 North, Range 34 West, in Weld
County, Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Condensate 003 Truck loadout of condensate. Emissions from the loadout
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. Within one hundred and eighty days (180) after issuance of this permit, compliance with
the conditions contained in this permit shall 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.
(Reference: Regulation No. 3, Part B, III.G.2).
2. This permit shall expire if the owner or operator of the source for which this permit was
issued: (i) does not commence construction/modification or operation of this source
within 18 months after either, the date of issuance of this construction permit or the date
on which such construction or activity was scheduled to commence as set forth in the
permit application associated with this permit; (ii) discontinues construction for a period
of eighteen months or more; (iii) does not complete construction within a reasonable
time of the estimated completion date. The Division may grant extensions of the
AIRS ID: 123/9CF8 Page 1 of 7
Condensate Loadout TM Version 2012-1
Co do p e o Public PollutionHealthand Control DivisionEnvironment
deadline per Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B,
I I I.F.4.)
3. The operator shall 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 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 AIRS Tons per Year
Equipment Point VOC Emission Type
ID
Condensate 003 60.0 Point
Loadout
See "Notes to Permit Holder"for information on emission factors and methods used to calculate
limits.
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
5. 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 Process Parameter Annual Limit
Point
003 Condensate Loading 393,720 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
AIRS ID: 123/9CF8 Page 2 of 7
flh Cali, do 9 p. e o Public Health and Environment
il
Air Pollution Control Division
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
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. This source is subject to the odor requirements of Regulation No. 2. (State only
enforceable)
8. 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.
c. The owner or operator shall inspect loading equipment and operations onsite at
the time of inspections to monitor compliance with Condition 8 (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.
9. 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
10. This source is not required to follow a Division-approved operating and maintenance
plan.
COMPLIANCE TESTING AND SAMPLING
11. This source is not required to comply with any testing and sampling requirements.
ADDITIONAL REQUIREMENTS
12. 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:
AIRS ID: 123/9CF8 Page 3 of 7
Co do p e o Pu and
D
Airblic PollutionHealth Control DivisionEnvironment
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 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.
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.
13. 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
I program threshold until a permit is granted. (Regulation No. 3 Part D).
GENERAL TERMS AND CONDITIONS
14. 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.
15. 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.
AIRS ID: 123/9CF8 Page 4 of 7
pColo do I p e o Public Health and Environment
II
Air Pollution Control Division
16. 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.
17. 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.
18. 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.
19. 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.
20. 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:
Stephanie Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc. Newly permitted
truck loadout at a true minor facility.
AIRS ID: 123/9CF8 Page 5 of 7
Co do pe o Public
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Air PollutionHealthand ControlEnvironment 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.crov/pacific/cdohe/aacc-reas
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.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(lb/yr)
n-Hexane 110543 C 1838 Yes 1838
008
Benzene 71432 A 210 No 210
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors -Uncontrolled
CAS Pollutant lb/1000 gal Source
loaded
VOC 7.2514 AP-42
110543 n-hexane 0.1111 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) = 7.61 psia
M (vapor molecular weight)=65 Ib/Ib-mol
T(temperature of liquid loaded)= 510°R
The uncontrolled non-criteria reportable air pollutant (NCRP) emission factors were calculated by
multiplying the mass fraction of each NCRP in the vapors by the VOC emission factor.
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
AIRS ID: 123/9CF8 Page 6 of 7
pCo 4 do a p e o Public Health and Environment
Air Pollution Control Division
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 Status
Requirement
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 XX)OCXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: http://www.colorado.gov/pacific/cdphe/air-permit-self-certification
AIRS ID: 123/9CF8 Page 7 of 7
Division Information
Engineer: Stephanie Chaousy,PE
Control Engineer: Chris Laplante
Review Date: 11/13/2014
Application Date: 06/26/2014 SCC Code 40600132:Crude Oil:Submerged Loading(Normal Service)
Facility Identifiers
Permit No. 14WE1221
County# 123 Weld
AIRS Facility# 9CF8
Point# 003
Section 01: Administrative Information
Company Name: PDC Energy,Inc.
Richter 34R-223,403,423;34U-
Source Name: 303/Richter 34M-203;34R-343
SESE Section 27,T7N,R34W
Source Location:
SIC: 1311
Elevation(feet)4870
Portable Source?
Portable Source Homebase
Mailing Address 1: PDC Energy,Inc.
Address 2: 1775 Sherman Street,Suite 3000
Address
City,State Zip: Denver,CO 80203
Name: Kelli Cox
Person To Phone: 303-860-5800
Contact Fax: 303-860-5838
Email: kelli.cox[pdce.com
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[psis]
M=molecular weight of vapors[lb/lb-motel
T=temperature of bulk liquid loaded[deg.RI
1 degree Fahrenheit=460.67 degree Rankine
S 0.6 Submerged loading:dedicated normal service
P 7.61 psia
M 65 lb/lb-mole
T 510 deg.R
7.25 lb/10^3 gal
3.05E-01 lb/bbl
Annual requested Throughput 16536240 gal/yr
Annual requested VOC emissions 119904 lb/yr
59.95 tpy
Regulatory Considerations
This facility is not condisdered a terminal(in Reg.7)because average daily throughput will
be below 20,000 gallons at 3,956 gallons per day.
This facility is not considered a bulk plant(in Reg.7)because it does not distribute
gasoline.
NCRPs
emission
emission factor
factor lb/1000
Component Mass Frac. emissions(I lb/bbt gal
Benzene 0.024 0.001752 210 0.000534 0.012702
n-hexane 0.21 0.015328 1838 0.004668 0.111147
STATE OF COLORADO
o6•Coro
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
ya
AIR POLLUTION CONTROL DIVISION N
TELEPHONE: (303)692-3150 4 *
"1876
CONSTRUCTION PERMIT
PERMIT NO: 14WE1226
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 Richter 34R-223, 403, 423; 34U-303/Richter 34M-203, 423;
34R-343, located in the SESE of Section 27, Township 7 North, Range 34 West, in Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
AIRS Description
Point
008 Twenty-one (21) 400 BBL fixed roof storage tanks used to store condensate.
Emissions from these tanks are controlled by an enclosed combustor.
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. Within one hundred and eighty days (180) after issuance of this permit, compliance with the
conditions contained in this permit shall 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. (Reference: Regulation
No. 3, Part B, III.G.2).
2. This permit shall 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; (Hi) does not complete construction within a reasonable time of the
estimated completion date. The Division may grant extensions of the deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
3. The operator shall 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.
(Reference: Regulation No. 3, Part B, Section III.E.)
AIRS ID: 123/9CF8 Page 1 of 10
Condensate Tank SM/M Version 2012-1
olo Depa e f bli Health and Environment
it Pollution Control Division
4. The operator in e ' I on le ' sued by the Division, after
completion of self-certification, with the most current construction permit. This construction
permit alone does not provide final authority for the operation of this source.
EMISSION LIMITATIONS AND RECORDS
5. Emissions of air pollutants 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:
AIRS Tons per Year
Point NO, Emission Type
•
VOC CO
008 -- 1.0 --- Point
See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
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.
6. The emission points in the table below shall be operated and maintained with the control
equipment as listed in order to reduce emissions to less than or equal to the limits
established in this permit (Reference: Regulation No.3, Part B, Section III.E.)
AIRS Pollutants
Control Device
Point Controlled
008 Enclosed combustor VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
7. 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
AIRS Process Parameter Annual Limit
Point
008 Condensate throughput 393,720 BBL/yr
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.
AIRS ID: 123/9CF8 Page 2 of 10
olor..k': Depa e ' f - bli Health and Environment
a: •it Pollution Control Division
Ili iir
STATE AND FEDE := G A=T ER.'a . " NTS ..,:..
8. The permit number and AIRS ID point number (e.g. 123/4567/890) shall be marked on the
subject equipment for ease of identification. (Reference: Regulation Number 3, Part B, III.E.)
(State only enforceable)
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. 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.)
10. This source is subject to the odor requirements of Regulation No. 2. (State only enforceable)
11. The flare covered by this permit is subject to Regulation No. 7, Section XII.C General
Provisions (State only enforceable). If a combustion device is used to control emissions of
volatile organic compounds to comply with Section XII.D, it shall 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. The operator shall comply with all applicable
requirements of Section XII.
12. This source is subject to the recordkeeping, monitoring, reporting and emission control
requirements of Regulation 7, Section XII. The operator shall comply with all applicable
requirements of Section XII.
13. The flare covered by this permit is subject to Regulation No. 7, Section XVII.B General
Provisions (State only enforceable). These requirements include, but are not limited to:
XVII.B.1.b If a flare or other combustion device is used to control emissions of volatile
organic compounds to comply with Section XVII, it shall be enclosed, have no visible
emissions during normal operations, 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. The operator shall comply with all applicable requirements of
Section XVII.
XVII.B.2.d.(ii)All combustion devices installed before May 1, 2014, must be equipped with an
operational auto-igniter by or before May 1, 2016, or after the next combustion device
planned shutdown, whichever comes first.
14. The storage tanks covered by this permit are subject to Regulation 7, Section XVII.C
emission control requirements. These requirements include, but are not limited to:
Section XVII.C.1. Control and monitoring requirements for storage tanks
XVII.C.1.b. Owners or operators of storage tanks with uncontrolled actual emissions of
VOCs equal to or greater than six (6)tons per year based on a rolling twelve-month
total must 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.
XVII.C.1.b.(i)(b) Control requirements of Section XVII.C.1.b. must be achieved by
May 1, 2015.
XVII.C.1.d. Beginning May 1, 2014, or the applicable compliance date in Section
XVII.C.1.b.(i), whichever comes later, owners or operators of storage tanks
AIRS ID: 123/9CF8 Page 3 of 10
olo Depa e f bli and Environment
it PollutionHealth Control Division
constr o s ectio I.C.1. must conduct audio,
visual, olfactory("AVO")and additional visual inspections of the storage tank and any
associated equipment (e.g. separator, air pollution control equipment, or other
pressure reducing equipment) at the same frequency as liquids are loaded out from
the storage tank. These inspections are not required more frequently than every
seven (7)days but must be conducted at least every thirty one(31)days. Monitoring
is not required for storage tanks or associated equipment that are unsafe,difficult,or
inaccessible to monitor, as defined in Section XVII.C.1.e. The additional visual
inspections must include, at a minimum:
XVII.C.1.d.(i) Visual inspection of any thief hatch, pressure relief valve, or other
access point to ensure that they are closed and properly sealed;
XVII.C.1.d.(ii)Visual inspection or monitoring of the air pollution control equipment to
ensure that it is operating, including that the pilot light is lit on combustion
devices used as air pollution control equipment;
XVII.C.1.d.(iii) If a combustion device is used, visual inspection of the auto-igniter
and valves for piping of gas to the pilot light to ensure they are functioning
properly;
XVII.C.1.d.(iv)Visual inspection of the air pollution control equipment to ensure that
the valves for the piping from the storage tank to the air pollution control
equipment are open; and
XVII.C.1.d.(v) If a combustion device is used, inspection of the device for the
presence or absence of smoke. If smoke is observed, either the equipment
must be immediately shut-in to investigate the potential cause for smoke and
perform repairs, as necessary, or EPA Method 22 must be conducted to
determine whether visible emissions are present for a period of at least one
(1) minute in fifteen (15) minutes.
XVII.C.1.e. If storage tanks or associated equipment is unsafe, difficult, or inaccessible to
monitor, the owner.or operator is not required to monitor such equipment until it
becomes feasible to do so.
XVII.C.2. Capture and monitoring requirements for storage tanks that are fitted with air
pollution control equipment as required by Sections XII.D. or XVII.C.1.
XVII.C.2.a.Owners or operators of storage tanks must route all hydrocarbon emissions to air
pollution control equipment,and must operate without venting hydrocarbon emissions
from the thief hatch (or other access point to the tank) or pressure relief device
during normal operation, unless venting is reasonably required for maintenance,
gauging, or safety of personnel and equipment. Compliance must be achieved in
accordance with the schedule in Section XVII.C.2.b.(ii).
XVII.C.2.b. Owners or operators of storage tanks subject to the control requirements of
Sections XII.D.2., XVII.C.1.a, or XVII.C.1.b. must develop, certify, and implement a
documented Storage Tank Emission Management System ("STEM")plan to identify,
evaluate, and employ appropriate control technologies, monitoring practices,
operational practices, and/or other strategies designed to meet the requirements set
forth in Section XVII.C.2.a. Owners or operators must update the STEM plan as
necessary to achieve or maintain compliance. Owners or operators are not required
to develop and implement STEM for storage tanks containing only stabilized liquids.
The minimum elements of STEM are listed below.
AIRS ID: 123/9CF8 Page 4 of 10
,0 II
Color ., Depa e .f • bli Health and Environment
it Pollution Control Division
XVII.C,�nw E , s,, st .e,, „ s-.,.,.? trol t- , .+logies, monitoring practices,
operational practices, and/or other strategies; procedures for evaluating
ongoing storage tank emission capture performance; and monitoring in
accordance with approved instrument monitoring methods following the
applicable schedule in Section XVII.C.2.b.(ii) and Inspection Frequency in
Table 1.
XVII.C.2.b.(ii) Owners or operators must achieve the requirements of Sections
XVII.C.2.a. and XVII.C.2.b. and begin implementing the required approved
instrument monitoring method in accordance with the following schedule:
XVII.C.2.b.(ii)(b) A storage tank constructed before May 1, 2014, must comply with
the requirements of Sections XVII.C.2.a. and XVII.C.2.b. by May 1, 2015.
Approved instrument monitoring method inspections must begin within ninety
(90) days of the Phase-In Schedule in Table 1, or within thirty(30) days for
storage tanks with uncontrolled actual VOC emissions greater than 50 tons
per year.
XVII.C.2.b.(ii)(d) Following the first approved instrument monitoring method
inspection, owners or operators must continue conducting approved
instrument monitoring method inspections in accordance with the Inspection
Frequency in Table 1.
Table 1 —Storage Tank Inspections
Threshold: Storage Tank Approved Instrument Phase-In Schedule
Uncontrolled Actual VOC Monitoring Method
Emissions (tpy) Inspection Frequency
> 6 and < 12 Annually January 1, 2016
> 12 and < 50 Quarterly July 1, 2015
> 50 Monthly January 1, 2015
XVII.C.2.b.(iii) Owners or operators are not required to monitor storage tanks and
associated equipment that are unsafe, difficult, or inaccessible to monitor,as
defined in Section XVII.C.1.e.
XVII.C.2.b.(iv) STEM must include a certification by the owner or operator that the
selected STEM strategy(ies) are designed to minimize emissions from
storage tanks and associated equipment at the facility(ies), including thief
hatches and pressure relief devices.
XVII.C.3. Recordkeeping
XVII.C.3. The owner or operator of each storage tank subject to Sections XII.D. or XVII.C.
must maintain records of STEM, if applicable, including the plan, any updates, and
the certification, and make them available to the Division upon request. In addition,
for a period of two (2) years, the owner or operator must maintain records of any
required monitoring and make them available to the Division upon request,including:
XVII.C.3.a. The AIRS ID for the storage tank.
AIRS ID: 123/9CF8 Page 5 of 10
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it PollutionHeahand ControlEnvironment Division
XVII.C.3.b.Th pe ' the t ' tch, pressure relief device,
or other access point are found to be venting hydrocarbon emissions, except for
venting that is reasonably required for maintenance, gauging, or safety of personnel
and equipment.
XVII.C.3.c. The date and duration of any period where the air pollution control equipment is
not operating.
XVII.C.3.d. Where a combustion device is being used, the date and result of any EPA
Method 22 test or investigation pursuant to Section XVII.C.1.d.(v).
XVII.C.3.e. The timing of and efforts made to eliminate venting, restore operation of air
pollution control equipment, and mitigate visible emissions.
XVII.C.3.f. A list of equipment associated with the storage tank that is designated as
unsafe, difficult, or inaccessible to monitor, as described in Section XVII.C.1.e., an
explanation stating why the equipment is so designated, and the plan for monitoring such
equipment.
OPERATING & MAINTENANCE REQUIREMENTS
15. Upon startup of these points, the owner or operator shall 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 O&M plan are subject to Division approval prior to implementation. (Reference:
Regulation No. 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
16. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 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 (1) minute in any fifteen (15) minute period during normal operation. (Reference:
Regulation No. 7 Section XVII.All)
Periodic Testing Requirements
17. The owner or operator shall demonstrate compliance with opacity standards, using EPA
Method 22 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 (1) minute in any fifteen (15) minute period during normal operation. (Reference:
Regulation No. 7 Section XVII.AII)
ADDITIONAL REQUIREMENTS
18. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No.3,
Part A, II.C)
a. Annually by April 301°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
AIRS ID: 123/9CF8 Page 6 of 10
Ill
olor 4 Depa e 4 bli Health and Environment
'it Pollution Control Division
lir
11
For vo „i'?!? ni ,• . v•• mirage '+es sources (NO,) 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.
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.
19. 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 Parts C and D).
GENERAL TERMS AND CONDITIONS
20. 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.
21. If this permit specifically states that final authorization has been granted, then the remainder
of this condition is not applicable. Otherwise, the issuance of this construction permit does
not provide"final"authority for this activity or operation of this source. Final authorization of
the permit must be secured from the APCD in writing in accordance with the provisions of
25-7-114.5(12)(a) C.R.S. and AQCC Regulation 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.
22. This permit is issued in reliance upon the accuracy and completeness of information supplied
by the owner or operator and is conditioned upon conduct of the activity, or construction,
installation and operation of the source, in accordance with this information and with
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.
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23. Unless specifi D g spe ' onditions contained in this
permit have been determined by the APCD to be necessary to assure compliance with the
provisions of Section 25-7-114.5(7)(a), C.R.S.
24. Each and every condition of this permit is a material part hereof and is not severable. Any
challenge to or appeal of a condition hereof 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.
25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution
Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and
administration. If a source or activity is to be discontinued,the owner must notify the Division
in writing requesting a cancellation of the permit. Upon notification, annual fee billing will
terminate.
26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention
and Control Act or the regulations of the AQCC may result in administrative, civil or criminal
enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil
penalties), -122.1 (criminal penalties), C.R.S.
By:
Stephanie Chaousy, PE
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc. Newly permitted
condensate tanks at a synthetic minor facility.
AIRS ID: 123/9CF8 Page 8 of 10
Ill
Color.:. Depa e .f - bli Health and Environment
`.! 'it Pollution Control Division
IF
Notes to Permit Holder - e of .er"'" "'tan
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 maybe 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/aocc-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.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(lb/yr)
Benzene 71432 A 142 No 7
Toluene 108883 C 92 No 5
008 Ethylbenzene 100414 C 6 No -
Xylenes 1330207 C 24 No 1
n-Hexane 110543 C 992 Yes 50
5) The emission levels contained in this permit are based on the following emission factors:
Point 008:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
Condensate Condensate
Throughput Throughput
NOx 0.1381b/mmbtu --- TCEQ
CO 0.276 lb/mmbtu --- TCEQ
VOC 2.4657 lb/1000 gal 0.1233 lb/1000 gal E&P Tanks
71432 Benzene 0.0086 0.00043 lb/1000 gal E&P Tanks
lb/1000 gal
108883 Toluene 0.0056 lb/1000 gal 0.00028 lb/1000 gal E&P Tanks
100414 Ethyl benzene 0.00036 lb/1000 gal 0.00002 lb/1000 gal E&P Tanks
1330207 Xylene 0.0015 lb/1000 gal 0.00008 lb/1000 gal E&P Tanks
110543 n-Hexane 0.05999 0.0030 lb/1000 gal E&P Tanks
lb/1000 gal
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olo Depa e f bli Health and Environment
it Pollution Control Division
Note: The co is ' poi ased combustor control efficiency of
95%.
6) In accordance with C.R.S. 25-7-114.1,each Air Pollutant Emission Notice(APEN) associated with this
permit is valid for a term of five years from the date it was received by the Division.A revised APEN
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 Status
Requirement
Operating Permit Synthetic Minor Source of:
VOC
NANSR Synthetic Minor Source of:
VOC
MACT HH 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.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 7777—Subpart MMMMM
MACT 63.8980-End Subpart NNNNN—Subpart XXXXXX
9) A self certification form and guidance on how to self-certify compliance as required by this permit may
be obtained online at: htto://www.colorado.novioacific/cdphe/air-riermit-self-certification
AIRS ID: 123/9CF8 Page 10 of 10
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: PDC Energy, Inc.
Permit Number 14WE1226
Source Location: Richter 34R-223,403, 423; 34U-303/Richter 34M-203,423; 34R-343
SESE Section 27,T7N, R34W, Weld County (non-attainment) •
Equipment Description: Condensate tanks
AIRS ID: 123-9CF8-008
Date: November 13, 2014
Review Engineer: Stephanie Chaousy, PE
Control Engineer Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
Section 3—Applicant Completeness Review
Was the correct APEN submitted for this source type? X Yes No
Is the APEN signed with an original signature? X Yes No
Was the APEN filled out completely? X Yes No
Did the applicant submit all required paperwork? X Yes No
Did the applicant provide ample information to determine emission rates? X Yes No
If you answered "no" to any of the above, when did you mail an
Information Request letter to the source?
On what date was this application complete? June 26, 2014
Section 4—Source Description
AIRS Point Equipment Description
008 Twenty-one (21) above ground 300 bbl atmospheric condensate storage tanks.
Emissions from these tanks are controlled by an enclosed combustor.
Is this a portable source? Yes X No
Is this location in a non-attainment area for any criteria X Yes No
pollutant?
If"yes", for what pollutant? PM10 CO X Ozone
Is this location in an attainment maintenance area for Yes X No
any criteria pollutant?
If"yes", for what pollutant?
(Note: These pollutants are subject to minor source PM1p CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Is this source located in the 8-hour ozone non-
attainment region? (Note: If"yes"the provisions of X Yes No
Regulation 7, Sections XII and XVII.C may apply)
Page 1
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
008 Source provided site-specific emission factors using a gas sample and E&P Tanks.
See Section 14 for calculations.
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTE)
AIRS Point Process Consumption/Throughput/Production
008 472646 BBL per year(393720 x 1.2)
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
008 393720 BBL per year 2013
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
008 393720 BBL per year
Does this source use a control device? X Yes No
%Reduction
AIRS Point Process Control Device Description
Greeted
008 01 Enclosed combustor 95
Section 6—Emission Summar/ (tons per year)
Point NO. VOC CO Single HAP Total HAP
PTE: 008 0.1 24.5 0.2 0.6 (Hexane) 0.7
Uncontrolled point 008 0.1 20.4 0.2 0.5(Hexane) 0.6
source emission rate:
Controlled point 008 0.1 1.0 0.2 0.02 (Hexane) 0.03
source emission rate:
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled meth° Controlled Emission
Pollutant CAS# BIN Emission Rate embalena
(lb/yr) reportable? Rate(lb/yr)
Benzene 71432 A 142 No 7
Toluene 108883 C 92 No 5
Ethylbenzene 100414 C 6 No -
Xylenes 1330207 C 24 No 1
n-Hexane 110543 C 992 Yes 50
Note: Regulation 3, Part A, Section II.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on potential emissions without credit for reductions achieved by control
devices used by the operator.
Section 8 Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory X Yes No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
008 01 Opacity Regulation No.7 Section XVII.AII) EPA Method 22
Page 2
Section 9—Source Classification
Is this a new previously un-permitted source? X Yes No
What is this facility classification? True X Synthetic Major
Minor Minor
Classification relates to what programs? X Title V PSD X NA NSR MACT
Is this a modification to an existing permit? Yes X No
If"yes"what kind of modification? Minor Synthetic Major
Minor
Section 10—Public Comment
Does this permit require public comment per CAQCC Regulation 3? X Yes No
If"yes",for which pollutants?Why?
For Reg. 3, Part B, III.C.1.a(emissions increase > 25/50 tpy)? X Yes No
For Reg. 3, Part B, III.C.1.c.ii (subject to MACT)? Yes X No
For Reg. 3, Part B, III.C.1.d(synthetic minor emission limits)? X Yes No
Section 11 —Modeling
Is modeling required to demonstrate compliance with National Ambient Yes X No
Air Quality Standards(NAAQS)?
If"yes", for which pollutants?Why?
AIRS Point Section 12—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
008 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.
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
008 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-APENs. Construction Permits, Operating Permits, PSD
Part A-APEN Requirements
Criteria Pollutants: For criteria pollutants, Air Pollutant Emission Notices are required for:
008 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
008 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)
Regulation 6- New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
Is this source greater than 19,800 gallons(471 bbl)? No
008 Is this source subject to NSPS Kb? No
WHY? Tanks do not meet the criteria of this requirement(tanks are 400 bbl; less than 471
bbl)therefore not subject to this subpart.
Page 3
Regulation 7—Volatile Organic Com&ounds
XII.VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is subject to the emission control requirements for condensate tanks
008 since it is located in a non-attainment area.)
XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are
greater than 20 tpy of VOC.)
Regulation 8—Hazardous Air
MACT EEEE: Organic Liquids Distribution
008 This source is not subject to MACT EEEE because it is not located at a major source of
HAP.
008 MACT HH
This source is not subject to MACT HH because it is not located at a major source of HAP.
Section 13—Aerometric Information Retrieval System Coding Information
Point Process Process Emission Pollutant/ Fugitive Emission Factor Source Control
Description Factor CAS# (Y/N) (%)
2.4657 E&P Tanks(engineering
lb/1000 gal VOC No calculation) 95
0.0086 Benzene/ E&P Tanks(engineering
lb/1000 gal 71432 No calculation) 95
0.0056 Toluene/ E&P Tanks(engineering
01 E&P Condensate lb/1000 gal 108883 No calculation) 95
008 Storage Tanks 0.00036 Ethylbenzene No E&P Tanks(engineering 95
lb/1000 gal /100414 calculation)
0.0015 Xylenes/ No E&P Tanks(engineering 95
lb/1000 gal 1330207 calculation)
0.05999 n-Hexane/ No E&P Tanks(engineering 95
lb/1000 gal 110543 calculation)
SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses
Section 14—Miscellaneous Application Notes
AIRS Point 008 Condensate Storage Tanks
Operator calculated site-specific emission factors using a gas analysis sampled 5/15/14 and E&P Tanks.
Gas analysis was sampled less than a year from submittal. A new gas analysis will not be required in the
permit.
Uncontrolled emission factors:
VOC= (20.384 TPY*2000)/393720= 0.103545667 lb/bbl * 1000/42=2.4657 lb/1000 gal
Benzene= (0.071 TPY*2000)/393720= 0.000360662 Ibibbl* 1000/42= 0.0086 lb/1000 gal
Toluene= (0.046 TPY*2000)/393720= 0.000233669 lb/bbl * 1000/42= 0.0056 lb/1000 gal
Ethylbenzene=(0.003 TPY*2000)/393720= 0.000015239 lb/bbl*1000/42=0.00036 lb/1000 gal
Xylenes= (0.012 TPY*2000)/393720=0.000060957 lb/bbl * 1000/42= 0.0015 lb/1000 gal
n-hexane= (0.496 TPY*2000)/393720= 0.002519557 lb/bbl * 1000/42= 0.05999 lb/1000 gal
Page 4
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c Air Pollutant Emission Notice(ADEN)-ind—Application for Construction Permit ,i
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY,A.7
Current Status(Che9l4 all that aonly)p Reason for APEN Submittal(Check all that apply) s"••••=):::- 1
AIRS ID#: 03--t:G6— 005 ❑ APEN update only F--- 2 2�s4
® New or previously unreported battery ❑ Modification to existing source" t�\ - ^,-'
/
❑ Previously grandfathered battery) ❑ Registration for coverage under general permit no.GP0'lN n 2
® Synthetic minor facility . &cancellation request for individual permits: N.
® Located in the 8-hr Ozone Control Area'' Ot Application for or Modification of an individual permit Is--`
❑ Registered under general permit no.GPO L.,- `:z,r,Lts,n Administrative permit amendments
❑ Permitted under individual permit:1:4(4.1C I-2:21:- a ❑ Other:
For individual permit applications,check if you want': ❑A copy of the preliminary analysis conducted by the Division
❑To review a draft of the permit prior to issuance
Company Names: PDC Energy,Inc. OGCC Operator#: 69175
Mailing Address': 1775 Sherman Street,Suite 3000
City: Denver State: CO Zip: 80203 E-mail: kelli.coxnndce.com
Contact Name: Kelli Cox Phone: (303)860-5800 Fax: (303)860-5838
Tank Battery Name II: Richter 34R-223,403,423;34U-303/Richter 34M-203,423;34R-343 Number of tanks: 21
Location" (QQ Sec.Twp.Range.): SESE 27 7N 34W County: Weld Total tank capacity[bbl]: 8400
Calendar year for which"Actual"data applies": 2013 Year(s)tank(s)were placed in service13: 2014
Control Description14: Combustor Control Efficiency": 95%
Condensate Throughput1s[bbl/year] Requested)': 393720 Maximum for PTE calculation": 472464
Actual": 393720 While Controls Operational"' 393720
Other equipment at facility":
Comments: APEN submitted to cover new facility
Estimated emissions at throughputs listed above. Use N/A for requested throughput/emission values unless requesting an individual permit
❑Check if the Division is to calculate emissions. ®Check if site-specific emission factors provided to calculate emissions'.
Emission Factor Battery Requested Emissions" Actual Emissions)'
Pollutant23 [lb/bbl] PTE'° Uncontrolled2' Controlled" Uncontrolled Controlled
VOC[tons/year] 0.1 24.5 20.4 1.0 20.4 1.0
NOx[tons/year] 0.138 lb/MIS/Btu N/A N/A 0.1 N/A 0.1
CO[tons/year] 0.276 lb/MMBtu N/A N/A 0.2 N/A 0.2
Benzene fibs/year] 0.0004 170.4 142.0 7.1 142.0 7.1
n-Hexane fibs/year] 0.003 1190.4 992.0 49.6 992.0 49.6
Wells serviced by this tank or tank battery'
API#: 05-123-36479 Name: Richter 34R-223 ®Newly Reported Well
API#: 05-123-36491 Name: Richter 34R-403 ®Newly Reported Well
API#: 05-123-36484 Name: Richter 34R-423 ®Newly Reported Well
API#: 05-123-37100 Name: Richter 34U-303 ®Newly Reported Well
API//: 05-123-36482 Name Richter 34M-203 ®Newly Reported Well
API#: 05-123-36486 Name: Richter 34M-423 ®Newly Reported Well
API#: 05-123-36487 Name: Richter 34R-343 ®Newly Reported Well
The signature below indicates that I have knowledge of the facts herein set forth and that the same are true,accurate,and complete to the best of
my knowledge and belief I this is a registration for coverage under general permit GP0I,I further certify that this source is and will be operated
in fu I qom liance with ea(h condition of general permit GPO).
Signaf(kd/of'I Bally Atiffi6rized Person(not a vendor or consultant) Date '
Kelli Cox EHS Professional
Type or Print Name of Person Signing Above Official Title
Submit this form,along with$152.90 for each Colorado Department of Public Health and Environment For information call:
filing of up to 5 tank battery APENS. Include Air Pollution Control Division,APCD-SS-Bl (303)692-3150
$250 General Permit fee for each new GP 4300 Cherry Creek Drive South 313647
registration to: Denver,CO 80246-1530
FORM APCD-205
Page 1 oft Cond.Tank APEN
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