HomeMy WebLinkAbout20141556.tiff STATE OF COLORADO
John W.Hickenlooper,Governor e co
Larry Wolk MD,MSPH o <_ t'z
Executive Director and Chief Medical Officer Ne,;
Dedicated to protecting and improving the health and environment of the people of Colorado .w �.
4300 Cherry Creek Dr.S. Laboratory Services Division r/876 s
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692.2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
www.colorado.gov/cdphe and Environment
Weld County - Clerk to the Board
1150 O St
PO Box 758
Greeley, CO 80632 RECEIVED
May 15, 2014 MAY 2 1 2014
WELD COUNTY
COMMISSIONERS
Dear Sir or Madam:
On May 18,2014,the Air Pollution Control Division will publish a public notice for PDC Energy Inc—
Waste Management 2Q-201,321;2T-221, 241,301,4W; 2Y-201, 441, in the The Greeley Tribune. 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 date the public notice is
published. Please send any comment regarding this public notice to the address below.
Colorado Dept. of Public Health & Environment
APCD-SS-B 1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Clara Gonzales
Regards,
it
Clara Gonzales
Public Notice Coordinator
Stationary Sources Program
Air Pollution Control Division
Enclosure
Paten) et: PLCMitA. at-065
22 I LI ?t t�1�f K, CtF iht) 2014-1556
5-21-t¢
STATE OF COLORADO
John W.Hickenlooper,Governor cif•coy
Larry Wolk,MD,MSPH mac. o Oqp
Executive Director and Chief Medical Officer
o
Dedicated to protecting and improving the health and environment of the people of Colorado
4300 Cherry Creek Dr.S. Laboratory Services Division *1876•
Denver,Colorado 80246-1530 8100 Lowry Blvd.
Phone(303)692-2000 Denver,Colorado 80230-6928 Colorado Department
Located in Glendale,Colorado (303)692-3090 of Public Health
•
www.colorado.gov/cdphe and Environment
Website Title: PDC Energy Inc—Waste Management 2Q-201, 321; 2T-221, 241,301,401; 2Y-201, 441 —Weld
County
Released To: The Greeley Tribune
On: May 15, 2014
Published: May 18, 2014
PUBLIC NOTICE OF A PROPOSED PROJECT
OR ACTIVITY WARRANTING PUBLIC COMMENT
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: Waste Management 2Q-201, 321; 2T-221, 241,301,401; 2Y-201, 441
wellpad
SESE Section 2,T2N, R64W
Weld County
The proposed project or activity is as follows: The applicant proposes a new wellpad with twenty-four(24)
400bb1 condensate tanks, eight(8)400bb1 produced water tanks, and associated loadout.
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.I.a
(25 tpy in a non-attainment area and/or 50 tpy in an attainment area)
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application,the Division's analysis, and a draft of Construction Permit 14WE0304 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 www.colorado.gov/cdphe/AirPublicNotices
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:
Rebecca Vasil
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-Bl
Denver, Colorado 80246-1530
cdphe.commentsapcd@state.co.us
STATE OF COLORADO
�0? cob_
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT f
Ne
AIR POLLUTION CONTROL DIVISION �'V
TELEPHONE: (303)692-3150 M L;;;_ ♦
•/$76+
CONSTRUCTION PERMIT
PERMIT NO: 14WE0304
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 Waste Management 2Q-201, 321; 2T-221,241,301,401;
2Y-201,441, located in the SESE of Section 2, Township 2N, Range 64W, in Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Twenty four(24) 400 BBL fixed roof storage tanks used to store
TK01 1-24 001 condensate. Emissions from these tanks are controlled by an
enclosed flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO 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 deadline per
Regulation No. 3, Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
AIRS ID: 123/9C50 Page 1 of 8
Condensate Tank SM/M Version 2012-1
olor Depa en f li Health and Environment
it Pollution Control Division
3. The operator • 4, pl I i ' m ting mpling 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.)
4. 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
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:
Facility AIRS Tons per Year
Equipment ID Point NO VOC CO Emission Type
x
TK011-24 001 0.46 5.6 0.91 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.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TK01 1-24 001 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
Facility
Equipment Point Process Parameter Annual
ID
TK01 1-24 001 Condensate throughput 510270
AIRS ID: 123/9C50 Page 2 of 8
olor Depa en f li Health and Environment
it Pollution Control Division
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.
STATE AND FEDERAL REGULATORY REQUIREMENTS
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 XVI1.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). 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.
14. The condensate storage tanks covered by this permit are subject to Regulation 7, Section
XVII emission control requirements. These requirements include, but are not limited to:
Section XVII.C. - Emission reduction from condensate storage tanks at oil and gas
exploration and production operations, natural gas compressor stations,
natural gas drip stations and natural gas processing plants.
XVII.C.1. Beginning May 1, 2008, owners or operators of all atmospheric condensate
storage tanks with uncontrolled actual emissions of volatile organic compounds
equal to or greater than 20 tons per year based on a rolling twelve-month total
AIRS ID: 123/9O50 Page 3 of 8
olor Depa en .f - _'Ii Health and Environment
•it Pollution Control Division
a-a e o co ' men ia, has an average control
efficiency of at least 95% for VOCs on such tanks.
XVII.C.3. Monitoring: The owner or operator of any condensate storage tank that is
required to control volatile organic compound emissions pursuant to this section
XVII.C. shall visually inspect or monitor the Air Pollution Control Equipment to
ensure that it is operating at least as often as condensate is loaded out from the
tank, unless a more frequent inspection or monitoring schedule is followed. In
addition, if a flare or other combustion device is used,the owner or operator shall
visually inspect the device for visible emissions at least as often as condensate
is loaded out from the tank.
XVII.C.4. Recordkeeping:The owner or operator of each condensate storage tank shall
maintain the following records for a period of five years:
XVII.C.4.a. Monthly condensate production from the tank.
XVII.C.4.b For any condensate storage tank required to be controlled pursuant
to this section XVII.C., the date, time and duration of any period where
the air pollution control equipment is not operating. The duration of a
period of non-operation shall be from the time that the air pollution control
equipment was last observed to be operating until the time the equipment
recommences operation.
XVII.C.4.c. For tanks where a flare or other combustion device is being used, the
date and time of any instances where visible emissions are observed from
the device.
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 Condition 9, 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 Condition 9, 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)
AIRS ID: 12319C50 Page 4 of 8
olor Depa nen 4f • WI Health and Environment
Air Pollution Control Division
ADDITIONAL REQ•, c N •
18. A revised Air Pollutant Emission Notice(APEN)shall be filed: (Reference: Regulation No. 3,
Part A, 'LC)
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(NOr) 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 or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential 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
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
AIRS ID: 12319C50 Page 5 of 8
• olor. Depa en f • di Health and Environment
it Pollution Control Division
f h in written docum= e . .�& =tt< ,.t=e..ri ils f'. =,'taining 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.
23. 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.
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:
Rebecca Vasil
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc.
AIRS ID: 12319C50 Page 6 of 8
olor5Y Depa en of ' .li "'Health and Environment
it Pollution Control Division
3
Notes to Permit Holder :h 1%. ' e o •e'` " ant-Y
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (lb/yr) reportable? Rate (Ib/yr)
Benzene 71432 A 1326 YES 66.3
001
Hexane 110543 C 8998 YES 449.9
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors Emission Factors
Uncontrolled Controlled
CAS # Pollutant Ib/BBL lb/BBL Source
Condensate Condensate
Throughput Throughput
VOC 0.4 0.02 Source
110543 n-Hexane 0.018 0.0009 Source
71432 Benzene 0.003 0.00015 Source
Note: The controlled emissions factors for point 001 are based on the flare control efficiency of
95%.
AIRS ID: 123/9C50 Page 7 of 8
Dep Health and Environment
6) In accordance with Ii7.RjoLEotPEN) associatedwiththis
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.znoaccess.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 M—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
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet.
Please use this form to complete the self-certification requirements as specified in the permit conditions.
Further guidance on self-certification can be found on our website at:
www.colorado.qov/cdphe/oilqaspermits
AIRS ID: 12319C50 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: PDC Energy, Inc.
Permit Number: 14WE0304
Source Location: SESE Sec. 2 T2N R64W,Weld county (non-attainment)
Equipment Description: 24-400bb1 condensate tanks
AIRS ID: 123-9C50-001
Date: February 28th 2014
Review Engineer: Rebecca Vasil
Control Engineer. Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
* If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first
being issued an Initial Approval permit
*Grandfathered exemption is for any tanks in service prior to December 30, 2002
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? February 5th 2014
Section 4—Source Description
AIRS Point Equipment Description
001 Twenty four(24) above ground 400 bbl atmospheric condensate storage tank
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 PM10 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
001 Source may provide site-specific emission factors using gas sample and E&P
Tanks. Will need to calculate emission factors from E&P Tanks.
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTEI
AIRS Point Process Consumption/Throughput/Production
001 612,324 BBL per year(510270 x 1.2)
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
001 463,000 BBL per year 2013
Basis for Permitted Emissions(Permit Limits),
AIRS Point Process Consumption/Throughput/Production
001 510,270 BBL per year
Does this source use a control device? Yes X No
% Reduction
AIRS Point Process Control Device Description
Granted
001 01
Section 6—Emission Summary (tons per year)
Point NO, VOC CO Single HAP Total HAP
PTE: 001 --- 135.4 --- 5.4 (n-Hexane) 6.19
Uncontrolled point 001 0.46 112.9 0.91 4.5 (n-Hexane) 5.16
source emission rate:
Controlled point 001 0.46 5.6 0.91 0.22 (n-Hexane) 0.26
source emission rate:
Section 7—Non-Criteria/ Hazardous Air Pollutants
Uncontrolled Are the Controlled Emission
Pollutant CAS# BIN Emission Rate emissionsreportable? Rate(Iblyr)
(Iblyr)
Benzene 71432 A 1326 Yes 66.3
n-Hexane 110543 C 8998 Yes 449.9
Note: Regulation 3, Part A, Section ll.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
VOC, Liquids Analyses
001 01 HAPS PS Memo 05-01 according to PS
Memo 05-01
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 X 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? Yes X No
If"yes",for which pollutants?Why? VOC
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
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,
001 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
001 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
001 Criteria Pollutants:
Applicant is required to file an APEN since emissions exceed 1 ton per year VOC
Part B—Construction Permit Exemptions
001 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 8, Section ll.D.3.a)
Regulation 6- New Source Performance Standards
NSPS Kb: for storage vessels greater than 19,800 gallons after 7/23/84.
001 Is this source greater than 19,800 gallons (471 bbl)? No
Is this source subject to NSPS Kb? No
Source is less than 471 bbl
Page 3
Regulation 7—Volatile Organic Compounds
XII. VOLATILE ORGANIC COMPOUND EMISSIONS FROM OIL AND GAS OPERATIONS
(Applicant is subject to the emission control requirements for condensate tanks
since it is located in a non-attainment area.)
001 XVII.C STATEWIDE CONTROLS FOR OIL AND GAS OPERATIONS...
(Applicant is currently subject to this since actual uncontrolled emissions are more
than 20 tpy of VOC.)
Regulation 8—Hazardous Air Pollutants
MACT EEEE: Organic Liquids Distribution
Pick one:
001 • This source is not subject to MACT EEEE because it is not located at a major
source of HAP.
MACT HH
Pick one:
001 • 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) (%)
9.5238
lb/1000 gal VOC No E&P Tanks 95
throughput
E&P Condensate 0'0714 Benzene/
01 Storage Tanks lb/1000 gal 71432 No E&P Tanks 95
001 throughput
0.429 n-Hexane
lb/1000 gal /110543 No E&P Tanks 95
throughput
SCC 40400311 —Fixed Roof Tank, Condensate,working+breathing+flashing losses
Section 14—Miscellaneous Application Notes
AIRS Point 001 Condensate Storage Tanks
This source is located in the 8-hour ozone non-attainment area(Weld County is in non-attainment).
Therefore, the provisions of Regulation 7, Section XII do apply to this source. The statewide
requirements of Regulation 7, Section XVII.C do currently apply to this source since actual uncontrolled
emissions are greater than 20 tpy.
Page 4
STATE OF COLORADO
OF COLD
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
� �
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303)692-3150 ‘*;:a/
� ��+.
CONSTRUCTION PERMIT
PERMIT NO: 14W E0305
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 Waste Management 2Q-201, 321; 2T-221,241,301,401;
2Y-201,441, located in the SESE of Section 2, Township 2N, Range 64W, in Weld County,
Colorado.
THE SPECIFIC EQUIPMENT OR ACTIVITY SUBJECT TO THIS PERMIT INCLUDES THE FOLLOWING:
Facility AIRS
Equipment Point Description
ID
Eight (8) 400 BBL fixed roof storage tanks used to store produced
TK02 1-8 002 water. Emissions from these tanks are controlled by an enclosed
flare.
THIS PERMIT IS GRANTED SUBJECT TO ALL RULES AND REGULATIONS OF THE COLORADO AIR
QUALITY CONTROL COMMISSION AND THE COLORADO AIR POLLUTION PREVENTION AND
CONTROL ACT C.R.S.(25-7-101 et seq),TO 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 deadline per Regulation No. 3,
Part B, III.F.4.b. (Reference: Regulation No. 3, Part B, III.F.4.)
AIRS ID: 123/9C50 Page 1 of 8
Produced Water Tank SM/M Version 2012-1
•
olor Depa en f li Health and Environment
it Pollution Control Division
3. The operator ;, ,_ ill I i m ting milling 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.)
4. 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
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:
Facility AIRS Tons per Year
Emission Type
Equipment ID Point NO, VOC CO
TK02 1-8 002 0.09 1.1 0.17 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.)
Facility AIRS Pollutants
Equipment Point Control Device Controlled
ID
TK02 14 002 Combustor VOC and HAPs
PROCESS LIMITATIONS AND RECORDS
7. This source shall be limited to the following processing rate 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
Facility
AIRS Annual
Equipment Point Process Parameter Limit
ID
TK02 14 002 Produced water throughput 164,970
BBL/yr
AIRS ID: 12319C50 Page 2 of 8
oA
.repa' en .if P i•li Health and Environment
it Pollution Control Division
The owner or Q.:, -i. sh ≥ c 4•r• '--s rate , ..ed 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.
8. Records shall be kept in either an electronic file or hard copy provided that they can be
promptly supplied to the Division upon request. All records shall be retained for a
consecutive period of three years.
STATE AND FEDERAL REGULATORY REQUIREMENTS
9. 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)
10. 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 ILA 1. & 4.)
11. This source is subject to the odor requirements of Regulation No.2. (State only enforceable)
12. Minor sources in designated nonattainment or attainment/maintenance areas that are
otherwise not exempt pursuant to Section II.D. of Regulation No. 3, Part B, shall apply
Reasonably Available Control Technology (RACT) for the pollutants for which the area is
nonattainment or attainment/maintenance. This source shall meet the requirements to apply
RACT and reduce emissions by installing and operating an enclosed combustor.
(Reference: Regulation No. 3, Part B, III.D.2.a).
OPERATING & MAINTENANCE REQUIREMENTS
13. Flares 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 flare, or by other
convenient means approved by the Division, determine whether the flare is operating
properly.
14. If a control device is used to comply with the emission limits of this permit, the following
conditions must be met:
a. Leakage of VOCs to the atmosphere must be minimized as follows:
(i) Thief hatch seals shall be inspected for integrity annually and replaced as
necessary. Thief hatch covers shall be weighted and properly seated.
(ii) Pressure relief valves (PRV) shall be inspected for proper operation
annually and replaced as necessary. PRVs shall be set to release at a
pressure that will ensure flashing, working and breathing losses are
routed to the control device under normal operating conditions.
AIRS ID: 123/9C50 Page 3 of 8
olor-A Depa en of sg)•li Health and Environment
sir Pollution Control Division
(iii) ns=- a;ef .- l.. d Ps 4 ,.:_Il be documented with an
indication of status, a description of any problems found, and their
corrective action.
15. Control devices shall be adequately designed, and operated and maintained according to
manufacturer specifications to achieve a control efficiency of at least 95%, and to handle
reasonably foreseeable fluctuations in emissions of VOCs. Fluctuations in emissions that
occur when the separator dumps into the tank are reasonably foreseeable.
16. The owner or operator shall monitor and document the proper operation of the control
device. Time intervals between monitoring shall not exceed 14 days. Indications of
improper operation for a flare include, but are not limited to, absence of pilot light,
malfunction of electronic ignition, and/or presence of smoke. A check box is suitable for
recording proper operation. Improper operation of a control device shall be further
documented with a description of the problem and its corrective action, the date range the
control was inoperable, and the produced water production through the battery during the
downtime. If the owner or operator cannot document the date that the control equipment
became inoperable then downtime shall be assumed to have started directly after the last
documented monitoring event. During control device downtime, emissions shall be
considered to be uncontrolled.
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
17. The owner or operator shall demonstrate compliance with Condition 10, 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)
Periodic Testing Requirements
18. No compliance requirements under this section.
ADDITIONAL REQUIREMENTS
19. A revised Air Pollutant Emission Notice(APEN)shall be filed:(Reference: Regulation No.3,
Part A, II.C)
a. Annually by April 30th whenever a significant increase in emissions occurs as follows:
For any criteria pollutant:
For sources emitting less than 100 tons per year, a change in actual emissions of
five (5) tons per year or more, above the level reported on the last APEN; or
For volatile organic compounds (VOC)and nitrogen oxides sources(NO.) in ozone
nonattainment areas emitting less than one hundred 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
AIRS ID: 12319C50 Page 4 of 8
4sr_
%olor Depa en f P li Health and Environment
it Pollution Control Division
For an rit le po futaat
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.
20. Federal regulatory program requirements (i.e. PSD, NANSR or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by virtue of
a relaxation in any permit condition. Any relaxation that increases the potential 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
21. 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.
22. 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.
23. 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.
24. 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.
25. 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
AIRS ID: 123/9C50 Page 5 of 8
olor Depa en f •°<I.li Health and Environment
it Pollution Control Division
regulations of ..,itu ' o 'QC st luding 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.
26. 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.
27. 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:
Rebecca Vasil
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc.
AIRS ID: 123/9C50 Page 6 of 8
z,
olo(.. - Depat. en ti • .li Health and Environment
Air Pollution Control Division
Notes to Permit Holder me o e "r°- an
1) The permit holder is required to pay fees for the processing time for this permit.An invoice for these fees
will be issued after the permit is issued.The permit holder shall pay the invoice within 30 days of receipt of
the invoice. Failure to pay the invoice will result in revocation of this permit(Reference: Regulation No. 3,
Part A, Section VI.B.)
2) The production or raw material processing limits and emission limits contained in this permit are based on
the consumption rates requested in the permit application. These limits may be revised upon request of
the owner or operator providing there is no exceedance of any specific emission control regulation or any
ambient air quality standard. A revised air pollution emission notice (APEN) and complete application
form must be submitted with a request for a permit revision.
3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense
Provision for Excess Emissions During Malfunctions.The owner or operator shall notify the Division of any
malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon
as possible, but no later than noon of the next working day, followed by written notice to the Division
addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:
http://www.colorado.gov/cs/Satellite?c=Document C&childpagename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(lb/yr)
Benzene 71432 A 1,160 YES 58
002
n-Hexane 110543 C 3,629 YES 182
5) The emission levels contained in this permit are based on the following emission factors:
Emission Factors Emission Factors
CAS# Pollutant Uncontrolled Controlled Source
Ib/BBL Produced lb/BBL Produced
Water Throughput Water Throughput
VOC 0.262 0.0131 CDPHE
110543 n-Hexane 0.022 0.0011 CDPHE
71432 Benzene 0.007 0.00035 CDPHE
Note: The controlled emissions factors for point 002 are based on the flare control efficiency of
95%.
AIRS ID: 123/9C50 Page 7 of 8
olor-� Depa en :f ill Health and Environment
it Pollution Control Division
6) In accordance with ;W-7-„u , ‘1111 Po sion (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
8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at
the website listed below:
httn://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
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit packet.
Please use this form to complete the self-certification requirements as specified in the permit conditions.
Further guidance on self-certification can be found on our website at:
www.colorado.qov/cdphe/oilqaspermits
AIRS ID: 123/9C50 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: PDC Energy, Inc.
Permit Number: 14WE0305
Source Location: SESE Sec. 2 T2N R64W,Weld county (non-attainment)
Equipment Description: 8.400bbl produced water tanks
AIRS ID: 123-9C50-002
Date: February 28 2014
Review Engineer: Rebecca Vasil
Control Engineer Chris Laplante
Section 2—Action Completed
Grandfathered Modification APEN Required/Permit Exempt
X CP1 Transfer of Ownership APEN Exempt/Permit Exempt
* If tank is a true minor source at a true minor facility, it may be granted "Final Approval"without first
being issued an Initial Approval permit
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? February 5th 2014
Section 4—Source Description
AIRS Point Equipment Description
002 Eight(8) above ground 400 bbl atmospheric produced water storage tank
Are "flash" emissions anticipated from these tanks? X Yes No
Is this tank located at an E&P site? X Yes No
Is this tank located at a non-E&P, midstream or Yes X No
downstream site?
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 PM10 CO Ozone
RACT per Regulation 3, Part B, Section III.D.2)
Page 1
Is this source claiming exempt status for this source
based on the fraction of oil in the stored water(less Yes X No
than 1% by volume crude oil on an average annual
basis)?
Are these produced water tanks located at a
commercial facility that accepts oil production Yes X No
wastewater for processing?
Are these produced water tanks subject to Colorado Oil
and Gas Conservation Commission (COGCC) 805 Yes X No
Rule?
If so, submit Form APCD-105
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
002 CDPHE Produced Water Storage Tank Emission Factors; CDPHE Memo 09-02
Did the applicant provide actual process data for the emission inventory? X Yes No
Basis for Potential to Emit(PTEZ
AIRS Point Process Consumption/Throughput/Production
002 164970 BBL per year
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production Data Year
002 135000 BBL per year 2013
Basis for PermItted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
002 164970 BBL per year
Does this source use a control device? X Yes No
% Reduction
AIRS Point Process Control Device Description
Granted
002 01 Combustor 95
Section 6—Emission Summary (tons per tear)
Point NO, VOC CO Single HAP Total HAP
PTE: 002 0.03 21.6 0.09 1'81 2.39
(Hexane)
Uncontrolled point 002 0.03 21.6 0.09 1.81 2.39
source emission rate: (Hexane)
Controlled point 002 0.03 1.1 0.09 0.09 0.12
source emission rate: (Hexane)
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Are the Controlled Emission
Pollutant CAS# BIN Emission Rate reportable?n.ei Rate(lb/yr)
(Iblyr)
Benzene 71432 A 1160 Yes 60
n-Hexane 110543 C 3620 Yes 180
Note: Regulation 3, Part A, Section lI.B.3.b APEN emission reporting requirements for non-criteria air
pollutants are based on actual emissions without credit for reductions achieved by control devices
used by the operator.
Page 2
Section 8—Testing Requirements
Will testing be required to show compliance with any emission rate or regulatory Yes X No
standard?
If"yes", complete the information listed below
AIRS Point Process Pollutant Regulatory Basis Test Method
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 X 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? VOC
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.iii (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
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,
002 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
002 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.
Page 3
Regulation 3-APENs, Construction Permits, Operating Permits, PSD
Part A-APEN Requirements
002 Criteria Pollutants:
Applicant is required to file an APEN since emissions exceed 1 ton per year VOC
Part B—Construction Permit Exemptions
002 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.3.a)
Regulation 6-New Source Performance Standards
002 None
Regulation 7—Volatile Organic Compounds
002 None
Regulation 8—Hazardous Air Pollutants
002 None
Section 13—Aerometric Information Retrieval System Coding Information
Point Process Process Description Emission Pollutant/ Fugitive Emission Factor Control
Factor CAS# (Y/N) Source (%)
6.2381
lb/1000 V0C No CDPHE PS 95
gallons Memo 09-02
throughput
0.1667
01 Produced Water Storage lb/1000 Benzene No CDPHE PS 95
002 Tanks gallons Memo 09-02
throughput
0.5238
lb/1000 n-Hexane No CDPHE PS 95
gallons Memo 09-02
throughput
SCC 40400315—Fixed Roof Tank, Produced Water,working+breathing+flashing losses
Section 14—Miscellaneous Application Notes
AIRS Point 002 Produced Water Storage Tanks
This source is located in the 8-hour ozone non-attainment area (Weld County is in non-attainment).
Page 4
'" ° �m �- .: 1 RBA"
x �
STATE OF COLORADO
c �
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT R6
AIR POLLUTION CONTROL DIVISION
TELEPHONE: (303) 692-3150 ° ?�,m+
•Isi6 4'
CONSTRUCTION PERMIT
PERMIT NO: 14WE0306
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 Waste Management 2Q-201, 321; 2T-221, 241, 301,
401; 2Y-201, 441, located in the SESE of Section 2, Township 2N, Range 64W, 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; (Ii) 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.)
AIRS ID: 123/9C50 Page 1 of 8
Condensate Loadout TM Version 2012-1
ID Col do p e o Public Health and Environment
Air Pollution Control Division
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 Emission Type
ID VOC
Condensate 003 69.3 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 510,270 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
AIRS ID: 12319C50 Page 2 of 8
i4 Col do a spari et o Public Health and Environment
Air Pollution Control Division
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 9 (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, I I.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
AIRS ID: 12319C50 Page 3 of 8
Col do p e o Public Health and Environment
Air Pollution Control Division
s zY3F
For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in
ozone nonattainment areas emitting less than 100 tons of VOC or NOx per
year, a change in annual actual emissions of one (1) ton per year or more or five
percent, whichever is greater, above the level reported on the last APEN; or
For sources emitting 100 tons per year or more, a change in actual emissions
of five percent or 50 tons per year or more, whichever is less, above the level
reported on the last APEN submitted; or
For any non-criteria reportable pollutant:
If the emissions increase by 50% or five (5) tons per year, whichever is less,
above the level reported on the last APEN submitted to the Division.
b. Whenever there is a change in the owner or operator of any facility, process, or
activity; or
c. Whenever new control equipment is installed, or whenever a different type of
control equipment replaces an existing type of control equipment; or
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 or Title V Operating Permit)
shall apply to this source at any such time that this source becomes major solely by
virtue of a relaxation in any permit condition. Any relaxation that increases the potential
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:
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
AIRS ID: 123/9C50 Page 4 of 8
ag—
` Col r do D pqr[ eny,- of Public Health and Environment
Air Pollution Control Division
the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC egulation 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.
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:
Rebecca Vasil
Permit Engineer
Permit History
AIRS ID: 123/9C50 Page 5 of 8
j\ }I91
oPublic Health and Environment
Air Pollution Control Division
Issuance Date Description
Issuance 1 This Issuance Issued to PDC Energy, Inc.
AIRS ID: 123/9C50 Page 6 of 8
rtr
Co do p rime oPublic 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: http://www.colorado.gov/cs/Satellite?c=Document C&childpaqename=CDPHE-
Main%2FDocument C%2FCBONAddLinkView&cid=1251599389641&pagename=CBONWrapper
4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process
limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis
of the specific compounds emitted if the source(s) operate at the permitted limitations.
Uncontrolled
Emission Are the Controlled
AIRS Rate emissions Emission
Point Pollutant CAS# BIN (Ib/yr) reportable? Rate(Ib/yr)
n-Hexane 110543 C 2120 Yes N/A
003
Benzene 71432 A 240 Yes N/A
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 6.46 AP-42
71432 Benzene 0.0113 AP-42
110543 n-Hexane 0.0991 AP-42
The uncontrolled VOC emission factor was calculated using AP-42, Chapter 5.2, Equation 1
(version 1/95) using the following values:
L = 12.46*S*P*M/T
S = 0.6 (Submerged loading: dedicated normal service)
P (true vapor pressure) = 6.68 psia
M (vapor molecular weight) = 66 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.
AIRS ID: 12319C50 Page 7 of 8
Co• do p e o Public Health and Environment
D . 1■� Air Pollution Control Division
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
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
9) An Oil and Gas Industry Construction Permit Self-Certification Form is included with this permit
packet. Please use this form to complete the self-certification requirements as specified in the permit
conditions. Further guidance on self-certification can be found on our website at:
www.colorado.gov/cdphe/oilgaspermits
AIRS ID: 123/9C50 Page 8 of 8
Construction Permit Application
Preliminary Analysis Summary
Section 1 —Applicant Information
Company Name: PDC Energy, Inc.
Permit Number: 14WE0306
Source Name: Waste Management 2Q-201, 321;2T-221, 241, 301,401; 2Y-201,441
Source Location: SESE Sec. 2 T2N R64W, Weld county (non-attainment)
Equipment Description: Truck Loadout
AIRS ID: 123-9C50-003
Review Date: February 28 2014
Review Engineer: Rebecca Vasil
Section 2—Action Completed
X CP1 Modification APEN Required/Permit Exempt
Final Approval 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? February 5th 2014
Section 4—Source Description
AIRS Point Equipment Description
003 Truck Condensate Loadout
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? PMio 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 PM10 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)
Is this source located at an oil and gas exploration site? X Yes No
Page 1
If yes, does this source load less than 10,000 gallons of
crude oil per day on an annual average, splash fill less
than 6750 bbl of condensate(hydrocarbons that have Yes X No
an API gravity of 40 degrees or greater) per year or
submerged fill less than 16,308 bbl of condensate per
year?
Is this source located at a facility that is considered a
major source of hazardous air pollutant (HAP) Yes X No
emissions?
Will this equipment be operated in any NAAQS X Yes No
nonattainment area?
Does this source load gasoline into transport vehicles? Yes X No
Section 5—Emission Estimate Information
AIRS Point Emission Factor Source
AP-42: Chapter 5.2, Equation 1
L= 12.46*S*P*M/T
003 L= loading losses in lb per 1000 gallons loaded
S = Saturation Factor
P =true vapor pressure of liquid loaded [psia]
M =molecular weight of vapors [lb/lb-mole]
T=temperature of bulk liquid loaded [deg. RI
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
003 510270 BBL per year condensate loaded
Basis for Actual Emissions Reported During this APEN Filing (Reported to Inventory)
AIRS Point Process Consumption/Throughput/Production
003 463000 BBL per year condensate loaded
Basis for Permitted Emissions(Permit Limits)
AIRS Point Process Consumption/Throughput/Production
003 510270 BBL per year condensate loaded
Does this source use a control device? Yes X No
Section 6—Emission Summary (tons per year)
Point NO„ VOC CO Single HAP HAP
PTE: 001 --- 69.3 --- 1.06 (n-hexane) 1.18
Uncontrolled point 001 --- 69.3 --- 1.06(n-hexane) 1.18
source emission rate:
Permitted point source 001 69.3 1.06 (n-hexane) 1.18
emission rate:
Section 7—Non-Criteria/Hazardous Air Pollutants
Uncontrolled Are the Controlled Emission
Pollutant CAS# BIN Emission Rate emissions Ibl r
(Ib/yr) reportable? Rate( y )
Benzene 71432 A 240 Yes N/A
n-Hexane 110543 C 2120 Yes N/A
Page 2
Note: Regulation 3, Part A, Section I1.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 Yes X No
standard?
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? VOC
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.iii (subject to MACT)? Yes 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)?
AIRS Point Section 12—Regulatory Review
Regulation 1 - Particulate, Smoke, Carbon Monoxide and Sulfur Dioxide
Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of
003 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. (Reference: Regulation No. 1, Section II.A.1. &4.)
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
003 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.
Page 3
Regulation 3-APENs, Construction Permits, Operating Permits, PSD
Criteria Pollutants:
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 ll.D.3.a)
003 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). Operator is using
submerged fill (0.6 saturation factor), therefore, RACT requirements are satisfied.
Regulation 6-New Source Performance Standards
003 No applicable subpart. This facility is not a bulk gasoline terminal.
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
003 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
003 None
Section 13—Aerometric Information Retrieval System Coding Information
Process/ Emission
Process Emission Pollutant/ Fugitive Control
Point Process Description throughput Factor CAS# (Y/N) Factor (oho)
Limit Source
6.46
01 Truck Condensate 510270 lb/1,000 V0C No AP-42 0
003 Loadout BBUyr gallon
throughput
SCC 40600132: Crude Oil: Submerged Loading (Normal Service)
Page 4
Section 14—Miscellaneous Application Notes
AIRS Point 003 Truck Condensate Loadout
Units Basis
S 0.6 Submerged loading:
dedicated normal service
based on source's
description/drawings
P 6.68 Psia Based on extended natural
gas sample OR based on
EPA TANKs run
M 66 Lb/lb-mole Based on extended natural
gas sample OR based on
EPA TANKs run
T 511 Deg R Based on source's
knowledge of bulk liquid
temperature OR based on
EPA TANKs run
L 6.46 Lb/10^3 gal Clarify if this value is used
to calculate annual
emissions or if
methane/ethane are
removed to represent VOC
vs TOC or if a safety factor
is applied OR any other
relevant notes
2.71 E-01 Lb/bbl
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 [psia]
M = molecular weight of vapors [lb/lb-mole]
T=temperature of bulk liquid loaded [deg. R]
L 6.461b/10^3 gal
2.71 E-01 lb/bbl
Annual requested Throughput 21431340ga1/yr
Annual requested VOC emissions 1385061b/yr
69.25tpy
Page 5
Air rouutant Emission iNonce tArr,iv)—aim — Application tor 1,onstrucnon rermrt
OIL AND GAS EXPLORATION AND PRODUCTION CONDENSATE STORAGE TANK BATTERY
rCurrent Status(Check all that appl') Reason for AI EN Submittal(Check all that apply)
AIRS ID 5: n23/9/-:-54a- (cc1 ❑ APEN update only'
® New or previously unreported battery ❑ Modification to existing source'
❑ Previously grandfmhered battery' ❑ Registration for coverage under general permit no.GPO) -
® Synthetic minor facility &cancellation request for individual permits:
® Located in the 8-hr Ozone Control Areal ® Application for or Modification of an individual permit
❑ Registered under general permit no. GPOI ❑ Administrative permit amendments
❑ Permitted under individual permit_ iS1..FCa- T. Gcl ❑ 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 S: 69175
Mailing Address9: 1775 Sherman Street,Suite 3000
City: Denver State: CO Zip: 80203 E-mail: kelli.coxn tdce.com
Contact Name: Kelli Cox Phone: (303)860-5800 Fax: (303)860-5838
Tank Battery Name10: Waste Management 2Q-201,321;2T-221,241,301,401;2Y-201,441 Number of tanks: 24
Location'' (QQ Sec.Twp. Range.): SESE Sec.2 T2N R64W County: Weld _ 'fetal tank capacity[bbl]: —9600
Calendar year for which"Actual"data applies'-: 2013 Year(s)tank(s)were placed in service'': -2013
Control Description': Combustor _-_ Control Efficiency's: 95%
Condensate Throughput1'[bbl/year] Requested's: 510270 Maximum for PTE calculation's: 612324
Actual'9: 463000 While Controls Operational20 510270
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 emissions2 .
Emission Factor Battery Requested Emissions's Actual Emissions19
I'o Ilutant''' ph/bbl] I'TL'4 Uncontrolled25 Controlled'° Uncontrolled Controlled
VOC [tons/year] 0.4 135.4 112.9 5.6 102.4 5.1
NOx (tons/year( 0.13816/MMBtu N/A N/A 0.46 N/A 0.4
CO [tons/year] 0.27616/MMBtu N/A N/A 0.91 N/A 0.8
Benzene[Ibs/year] 0.003 1591.2 1326.0 66.3 1203.2 _ 60.2
n-Hexane[lbs/year] 0.018 10797.6 8998.0 449.9 8164.5 408.2
Wells serviced by this tank or tank battery"
Apl 4S: 05-123-36963 Name: WASTE MANAGEMENT 2Q-201 ®Newly Reported Well
Apl a: 05-123-36966 Name: WASTE MANAGEMENT 2Q-321 ®Newly Reported Well
ApI g: 05-123-36964 Name: WASTE MANAGEMENT 2T-221 ®Newly Reported Well
API/1: 05-123-36967 Name: WASTE MANAGEMENT 2T-241 ®Newly Reported Well
API d: 05-123-36962 _ Name WASTE MANAGEMENT 2T-301 _ ®Newly Reported Well
API II: 05-123-36961 Name: WASTE MANAGEMENT 2T-401 ®Newly Reported Well
API 05-123-36986 Name: WASTE MANAGEMENT 2Y-201 ®Newly Reported Well
API;;: 05-123-36965 Name: WASTE MANAGEMENT 2Y-441 ®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 beliefierNlf this is a registration for coverage under general permit GPOI,I further certify that this source is and will be operated
in fult om li c with/fad'condition of general permit GPOI.
�I v _ ,14,(,LA
Signat re of Legally uthorized Person(not a vendor or consultant) at
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-B 1 q 4 (303)692-3150
$250 General Permit fee for each new GP 4300 Cherry Creek Drive South 30517
registration to: Denver, CO 80246-1530
FORM APCD-205
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