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Home My WebLink About20202660.tiff COLORADO Y� Department of Public cDP"E Health a Environment RECEIVED AUG 0 4 2020 WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board 1150O St PO Box 758 Greeley, CO 80632 July 29, 2020 Dear Sir or Madam: On July 30, 2020, the Air Pollution Control Division wilt begin a 30-day public notice period for PDC Energy, Inc. - Wilmoth 5 Sec HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator 4300 Cherry Creek Drive S., Denver,CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe i ,'.7l ,s,, Jared Polls,Governor I Jilt Hunsaker Ryan,MPH, Executive Director .L--, '.,' Pc/61; c Re r;e W cc:PL(TP),E-lLCDs),Pii4LrM/E>R/criicK), 2020-2660 O9/02/2O o(,(sM) ©`f f6/2A r.....4.1,14g. Air Pollution Control Division Notice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: PDC Energy, Inc. - Wilmoth 5 Sec HZ - Weld County Notice Period Begins: July 30, 2020 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: Wilmoth 5 Sec HZ Well Production Facility NWNW of Section 5, Township 4N, Range 64W Weld County The proposed project or activity is as follows: PDC Energy Inc. is requesting permit coverage for twelve (12) 538 barrel fixed roof condensate storage vessels and one (1) surge vessel at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area. 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 Permit 20WE0192 Et 20WE0602 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. Comments may be submitted using the following options: • Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 _,,....„ COLORADO Department of Public 1 I c"" Health Fr Environment Denver, Colorado 80246-1530 COLORADO 2 �""`440 Department of Public Health&Environment O I Air Q Pollution R A �?Control Division CUPNF Dtvaqrne,it o Pubic FiedJth smruvrte-;i Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0192 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: Wilmoth 5 Sec HZ Plant AIRS ID: 123/A008 Physical Location: NWNW SEC 5 T4N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Twelve (12) 538 barrel fixed roof Enclosed TK-1 001 condensate storage vessels connected via Combustor(s) liquid manifold. 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 the specific 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) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must 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. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must 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 Page 1 of 10 - € CO! COLORADO lution Control vision CDPHE De0afltneal2 0'Put'b Kean&_ra rt_rvtleni Dedicated to protecting and improving the health and environment of the people of Colorado more; (iii) does not complete construction within a reasonable time of, the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 3. The operator must 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. (Regulation Number 3, Part B, Section III.E.) 4. The operator must 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 must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type TK-1 001 --- 1.4 13.2 3.0 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK-1 001 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made Page 2 of 10 •-�z ! COLORADO Air Pollution Control Division C©PHE a Detzaar'.tYen:ce PuLtr_Me31rtl Er Er7viru rrte"t Dedicated to protecting and improving the health and environment of the people of Colorado available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) .A.4.) Process Limits Facility AIRS Equipment Point Process Process Parameter Annual Limit ID Condensate throughput routed directly from the 01 three-phase 181,865 barrels TK-1 001 separators to the condensate storage vessels 02 Combustion of pilot 1.8 MMSCF light gas The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must 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 must 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 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)I.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank 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. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. 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 II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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 Page 3 of 10 `.-•-,�.,� ! COLORADO Mr Pollution Control Division CDPH L aarnrn2 Pubic F-f Oh$Ervombsr A Dedicated to protecting and improving the health and environment of the people of Colorado means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and 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 except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 16. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OEtM) 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 the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 4 of 10 ,,, •- . I COLORADO ' 14,061 I Air Pollution Control Division CDens De willt-li&Publr_'tieaJ.t]6_fvliutvrle:l Dedicated to protecting and improving the health and environment of the people of Colorado 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. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Facility Equipment ID AIRS Equipment Pollutant Current Point Description Threshold Permit Limit Condensate TK-1 001 Storage Vessels NOx 50 14.5 Hydrocarbon VOC 50 36.1 LOAD-1 002 Loadout Page 5 of 10 -•,..4.y COLORADO , , Mr Pollution Control Division G6PHE DeParirTwnt a'Pak eke b trtvvcxvrren1 Dedicated to protecting and improving the health and environment of the people of Colorado ENG-1 003 SI RICE ENG-2 004 SI RICE ENG-3 005 SI RICE ENG-4 006 SI RICE ENG-5 007 SI RICE Surge Vessel 009 Separator ___ ___ Insignificant Sources Note: The insignificant sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. 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 Number 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 Number 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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 Page 6 of 10 g , { coLORADO Mr Pollution Control Division • CDPHE Ctr' =Yrt}eTtt a'Rut!,_ lea], 6 Sic,/ne' Dedicated to protecting and improving the health and environment of the people of Colorado 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Permit for twelve (12) condensate storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 10 I COLORADO Pollution ol Division f©PHE Depa tnegl 0 PuLIc_}{C!Oi&En ert,ruile-i7 Dedicated to protecting and improving the health and environment of the people of Colorado 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 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 must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,751 88 Toluene 108883 1,538 77 Ethylbenzene 100414 43 3 001 Xylenes 1330207 572 29 n-Hexane 110543 11,661 583 2,2,4- 540841 46 3 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Process 01: Condensate throughput routed directly from the three-phase separators to the storage vessels Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 1.46x10-2 1.46x10-2 TNRCC Page 8 of 10 - , ( COLORADO . Air Pollution Control Division CDPHE a D 3r'wieni c,%W S.F fealet&Cn urdrvi-l. Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 2.914x10-2 2.914x10-2 TNRCC VOC 2.8833 1.442x10-1 ProMax 71432 Benzene 9.627x10-3 4.814x104 ProMax 108883 Toluene 8.455x10-3 4.228x10-4 ProMax 1330207 Xylene 3.145x10-3 1.572x10-4 ProMax 110543 n-Hexane 6.412x10-2 3.206x10-3 ProMax Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the outlet of the low pressure separator for the Wilmoth E 5A-232 well on 12/10/2019. The sample pressure and temperature are 31.3 psig and 114°F respectively. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a gas molecular weight of 42.8523 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, a VOC mole%of 58.38277%and a heat content of 2,418.734 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput routed directly from the three-phase separators to the storage vessels. Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/MMSCF lb/MMSCF NOx 77.25 77.25 AP-42 Chapter 13.5 CO 352.16 352.16 AP-42 Chapter 13.5 VOC 6.13 6.13 AP-42 Chapter 1.4 Table 1.4-2 Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,136 Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4 emission factor by a ratio of 1,136 Btu/scf to 1,020 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 15.6 scf/hr. There are a total of thirteen combustors used to control emissions from the condensate storage vessels. As a result, the total pilot light gas fuel flow is 202.8 scf/hr. Total actual emissions are obtained from the sum of emissions resulting from the storage vessels and combustion of waste gas from the storage vessels (process 01) and the combustion of pilot light gas (process 02). 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 must be submitted no later than 30 days before the five-year term expires. Please Page 9 of 10 RO '. .z Air Plluti n AD t of ivision -DP HE Dectirtrrit,,ii cA Tubb_tiealbh&Er'iv,rt.fun=„ Dedicated to protecting and improving the health and environment of the people of Colorado 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 permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, a NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC a NOx MACT HH Area Source Requirements: Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A- Subpart UUUU 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 Page 10 of 10 , COLORADO I Air Pollution Control Division GDPH I Cv.aerrten %IAbk.F repe Ex En rLnitytr,i Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0602 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: Wilmoth 5 Sec HZ Plant AIRS ID: 123/A0C8 Physical Location: NWNW SEC 5 T4N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description Natural gas flaring from one (1) surge Enclosed Surge Vessel 009 vessel during vapor recovery unit (VRU) Combustor(s) downtime. 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 this specific 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) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must 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. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphefair-permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must 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 Page 1 of 10 4 ICOLORADO ! Air Pollution Control Division t rtet,AfErtetS Jf Putifv.tfealtf b_ns,ru#dne": Dedicated to protecting and improving the health and environment of the people of Colorado 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. (Regulation Number 3, Part B, Section III.F.4.) 3. The operator must 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. (Regulation Number 3, Part B, Section III.E.) 4. The operator must 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 must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO VOC CO Type X Surge Vessel 009 --- 0.6 6.6 1.1 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must 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 must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Emissions from the surge vessel are routed Surge Vessel 009 to Enclosed Combustor(s) during Vapor VOC and HAP Recovery Unit (VRU) downtime Page 2 of 10 �.•s� ' COLORADO Air Pollution Control Division G6PHE aew-oeall c Pub:r_HealrI @_r}drr r'm Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point Surge vessel hydrocarbon Surge Vessel 009 liquid throughput during 90,933 barrels vapor recovery unit (VRU) downtime. The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must 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 must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall monitor and record surge vessel vapor recovery unit (VRU) downtime on a daily basis. Surge vessel VRU downtime shall be defined as times when waste gas vented from the surge vessel is routed through the storage vessels to be controlled by the enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total hydrocarbon liquid throughput routed through the surge vessel during VRU downtime, and total hydrocarbon liquid throughput through the surge vessel shall be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly surge vessel hydrocarbon liquid throughput records and the calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device Page 3 of 10 4- COLORADO Mr Pollution Control Division cae«E 4 tan' enEa2 o.'Tubb. realPa&rrivrcivrtt.::It Dedicated to protecting and improving the health and environment of the people of Colorado is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; 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. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by 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. 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Ft MAINTENANCE REQUIREMENTS 15. Upon startup of this point, the owner or operator must follow the most recent operating and maintenance (OUM) 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 the O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS Page 4 of 10 ._, - ! COLORADO I Air Pollution Control Division CaPH I Del.`art?ient PUbI>_'tteaJrh&:rretutVriewil Dedicated to protecting and improving the health and environment of the people of Colorado 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOX) in ozone nonattainment areas emitting less than 100 tons of VOC or NO. per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less,above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Facility Equipment ID Pollutant Emissions - tons per year Page 5 of 10 ' COLORADO Air Pollution Control Division CDPiiE E marrie_e of Put4r title I i h cnwu.orMea Dedicated to protecting and improving the health and environment of the people of Colorado AIRS Equipment Current Point Description Threshold Permit Limit Condensate TK-1 001 Storage Vessels LOAD-1 002 Hydrocarbon Loadout ENG-1 003 SI RICE ENG-2 004 SI RICE NOx 50 14.5 ENG-3 005 SI RICE VOC 50 36.1 ENG-4 006 SI RICE ENG-5 007 SI RICE Surge Vessel 009 Separator _ Insignificant -- Sources Note: The insignificant sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. 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 Number 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 Number 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 Page 6 of 10 4i0ICOLORADO } I Air Pollution Control Division P Dmafirnent PLINK 1 fedJ?ti trpv r rvtn Dedicated to protecting and improving the health and environment of the people of Colorado 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 must constitute a rejection of the entire permit and upon such occurrence, this permit must 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: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issued to PDC Energy, Inc. Issuance 1 This Issuance Permit for one (1) surge vessel at a new synthetic minor well production facility. Page 7 of 10 COLORADO Air Pollution Control Division OP Depal.nent o Pubb,_Health e_ wrottt5eg Dedicated to protecting and improving the health and environment of the people of Colorado 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 must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 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 must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr)' Benzene 71432 876 44 Toluene 108883 769 39 Ethylbenzene 100414 22 1 Surge Vessel 009 Xylenes 1330207 286 15 n-Hexane 110543 5,831 292 2,2,4- 540841 23 2 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 009: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 1.14x10-2 1.14x10-2 TNRCC Page 8 of 10 a` x�' COLORADO Air Pollution Control Division C)PHF i ' ,u>T5ent o,Pubic FtePh b_trviscg,ne•J1 Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 2.28x10-2 2.28x10-2 TNRCC VOC 2.8833 1.442x10-1 ProMax 71432 Benzene 9.627x10-3 4.814x10-4 ProMax 108883 Toluene 8.455x10-3 4.228x10-4 ProMax 1330207 Xylene 3.145x10-3 1.572x104 ProMax 110543 n-Hexane 6.412x10-2 3.206x10-3 ProMax Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the outlet of the low pressure separator for the Wilmoth E 5A-232 well on 12/10/2019. The sample pressure and temperature are 31.3 psig and 114°F respectively. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively)in the table above were converted to units of lb/bbl using a GOR of 34.15 and a heat content of 2,418.734 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon liquid throughput routed through the surge vessel during VRU downtime. 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 must 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, CO Et NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Et NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 9 of 10 .�.-je _ . ' COLORADO .�"�- Air Pollution Control Division CDPHE Ci f`,artMent d Rubl Heylth 8 Lrivvvvr),?r-; Dedicated to protecting and improving the health and environment of the people of Colorado 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 Page 10 of 10 Coiorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package#: 424902 Received Date: 12/31/2019 Review Start Date: 4/6/2020 Section 01-Facility Information Company Name: PDC Energy,inc. Quadrant Section Township Range County AIRS ID: 123 NWNW 5 4N 64 Plant AIRS ID: AOCE Facility Name: Wilrnoth5 Sec HZ Physical Address/Location: County: Weld County Type of Facility: E'xpioratian&Production Well Pad What industry segmenttOil&Natural Gas Production&processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks assigned) assigned) `Permit Initial 001 Condensate Tank TK-1 Yes 20WE0192 1 Yes - Issuance Section 03-Description of Project PDC Energy,Inc,(PDC)is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non- .attainment area.With this application,the operator is requesting permit coverage for a surge vessel,condensate storage vessels,hydrocarbon liquid loadout and engines.The hydrocarbon liquid)oadout and engines are requesting general permit coverage_This analysis only evaluates the condensate storage vessels. This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 5,Part A,Section ILB.3.a,).Additionally,the source is permit required because the uncontrolled VOCemissions from at APEN required sources at the facility are greater than 2 tpy(COAQCCRegulation 3,Part B,Section lICt 2.a.) Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements,and the change in VOC emissions as a result of this project is greater than 25 tpy. - - - - Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? tu. tirigsynthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeing analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration IPSO) ❑ ❑ ❑ ❑+ ❑ ❑ Title V Operating Permits(OP) ❑ lB 200 ❑ ❑ ❑ Non-Attainment New Source Review(NANSR) LI 0 Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) CI ❑ ❑ ❑ ❑ ❑ Title V Operating Permits(OP) ❑ 1] ❑ ❑ ❑ ❑ ❑ ❑ Non-Attainment New Source Review(NANSR) ❑ 111 ':-id''(-)Emis.siens fo- ertor,, Seedon 01-Administrative Information LFacility Allis ID: ..323 AtiCB Oov _ County PIanI Point Section 02-Eoulpment Description Details Detailed Emissions one Tweive(12)538 barrel tined nde0001a st g v esels connected ti a liquid manifold••• ^3 T Descr pt on: ,.'1 m.;4 441'4)644%4•14=a, Emssion Control Device 1 qfr oescrlP[an. "0'00ed<mbustons7 €ro Requested Overall VOC&HAP Control Efficiency%: Seaton 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tenk(s) Actual CandensateThroughput= ' 'A eO Barrels(bbl)peryear 'Requested Permk Limit Throughput= -o 11&X865t,MBarrels(bbl)peryear Requested Monthly Throughput= 1-4,16:1 Barrels(bbl(per month Potential to Emit(PTE)E9ndensate Thro ghpot pPAP. = A2/y$ .,R Barrels(Ishii per year Secondary Emissions.Combustion Device(s) Heat content of waMe gas f Btu/scf Volume of wastages emitted per BBL of liq ld ,"s y�' produced= *ESy scf/bbl Actual heat content of waste gas routed.combustion d — "" 8. 31*MMDrU peryear • Requestedheatcontentofwastegesroutedtocombustiondevice= 19..1.1,.MMBTU per year Potential to Emit(P14)heat content of waste gas routed to combustion device= .,,.;1.2::??MMBfU peryear Control Device Number of Combustors: Plot Fuel Use Rate X�,y ={ b05;sdh ^I MNIscf/yr Plot Fuel Gas Heating Value: `v0 _S S-11.14,I'etu/sd __-_55 MMBTU/yr Section 04-Emissions Factors&Methodologies Will this rtorage tank emit flash emirs ions0 ProMax Flow Rate 227,332 00 bbl/year Pollutant Plaan Gal(ro/nrI W&B Gas Total Waste Gas Source (lb/hr) Rate(Ib/hr) VOC 56.14155251 18.6826484 ,_ ccP^^ro�Man Benzene • 0.200905 0.0439265 a rPrnMeo Toluene a, 0.178805 ..0.0406108 _- ProMax Ethylbenzene 000486813 0.0121251 P.M. %Hones 00614845 0.0201208 ..... FroMax n-Hexane 1.26136... 0.402511: 2r0Men 2,2,4-TMP 000496713 0.00154603 - PraMax Uncontrolled Controlled Pollutant (16/661) (lb/bbl) Emission Factor Source omen:are Con•en a. Throughput) Threughpot) • • JLiIR Uncontrolled Uncontrolled Poilurent Emission Factor Source waste eat Con.ensa[e combus[ed) Throughput( 0.00)5 AP 4YSaUJ§ .:0.00]5MIMERP 42 T#414-4,F4.9.444,442:, NkCtr. V Uncontrolled Uncontrolled Pollutant (Ib/MMetul lib/MMscf) Emission Factor source Waste Heat Pia[Gas ombusted) Throughput) " ; ll =' AUGUR. . 3 wry '° 60054, “f6VriV14.4441,att*Vik,1;:iii SeWon 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (ions/year) (tons/year) (tons/year) (Ibs/month) VOC PM2.5 _ 71 NDx CO Potential to Emk Actual Emissions Requerted Pone Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) (Ibs/year) Iluolyear) (Ihs/year) (Ibs/year) Benzene - Toluene :. Ethylbenzene .. %Hone n-Hexane - - 224IMP ... 2 of 4 C:\Users\hslaught\Desktop\12340C8\20W E0192.CP1 Contlensate section 6-Regulatory Summon,Analysis Regulation 3,Parts A,e sap. Regulation],Section%Pc,O,E,F Regulation 7,Section C e Regulation 7,Sefton XVII.B,C.1,C.3 .> a a r._.i Regulation J,Sefton Preow T e sspect Putstat.an Te._ Regulation 6,Part A,NSPS Subpart Kb • Regulation 6,Part A,NSPS Subpart 0000 Swww s Tor.to.....gsas_.;..- NSPS Subpart 0000a -- j Regulation B,Part E,MACTSubpart HP (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirement. Does the company use the state defaulenresiane factors to estimate emissions? Byes,arethe uncontrolled actual or requested emissions estlmatedto be greaterthan or equal.,80 tons 005 per year? N/A-the operator developed site specific emission factors. If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in-PS Memo 05-01.�� Does the p y use a site specific emissions factor to estimate emissions? ▪7i If yes d if there areflash emissions,a i factors based on a pressurized llq d sample drawn at the `M0 facility being permitted?This sample should b d d representative which generally means site-specific and "aid s= a:°-Beg.g. collected within one year of the applicatianirecetvedot However,fihefacliry has not been modified(e.g.,no new TyyKy,SNgagg v A? wells brought on-line),then h may be app ptaxeto use an olderste-specife sample ,Sr«ry,�' If no,the permit will contain an"Initial Come tet00e"testfng requirement to develop a site spec fcemissions factor based on guidelines re PS Memo 05-01. DOes the,thecompany request sin etdrol dev ceeff cenry greaterthan 95°h fora Flare Orcombustion device? a H yes,the permit will contain and initial compliance test condition to demonstrate the destruction efficiency of the Comb▪ustion device based on inlet and outlet concentration sampling 5 Technical Analysis Notes 1 Typically,the secondary combustion calculated using thewaste gasflow rate and heat content predicted by them del used to establish the ste-spoof! ons factors eased on the P 02 ,mutation thet0talwaste Basfiow rate was predicted to be 0021270000f/day(Flash and W&3 gas).Addrtonally,en average het content was determined using the heat content of theflasb gas stream(2050.21 Bta/sof)endthe W&B stream(250548 Btu/scf)and the f llowing equations: Average Heat 00010001(2391:21Btu/srff"(Q.01S147S MMsef/day]/(0.021271 MMicf/day(!+[(2505.44 8Yu/sr]'(00051235 MMzcf/day)/(0 021224 MMsef/day(]=2418 734 Btu/Scf Utng thsnformaYOn,the yearly heat input 0f Olegas would be calculate)sfollo s:Hest Input(MMOte/yr)-(0021271 MMscf/day(°(365day/year)°(2418234MM8tu/MMscf)°(151,555 bbl(Year)/(22J332bbl/year)=12,519258MM0tu/year Using the value,the actual Not and CO emistiana wood be calculated at086tpy and l.72 tidy respectively. The operator used tbefollowng equation to calculatethe actual annual heatinput:Heat Input(MMBtu/yr),(Uncontrolled VOClton/yrl]°(2000lb/ton!/IMWlibiliveml(t°tad9.41 sof/lb-mol]•(1/VOCmtlI 0]1Fleal Content(Btu/acf/°llMMBtu/1,0000008t).:The operator expressetl the values for molecularweight and VOC mal%used intne equationwere°Mauled from the flash gas stream and the heat -content was obtained from theaverage of the flash gas stream and the SVABstream in the ProNlax simulation provided in the application.The values usedin the equation are as follow:(i)Molecular WeghY 428523Ib/ib-mol(ii)0000014 0805747004 I')Heat Conte. 2418.7139.6P Btu/scf Usegtl esevalues,the operator cagulated'a heat input of 10,028.52141 MMBtu/yr.Sinee th&value is More conswyetivethanthe value calwlaced above using Fl cMed met nods,itwin be used f r p500,10na p21 r00s ,2 The s0Lspeciflc sample used 10 establish m ens factors for the source was obtanedwahn a year of the applaton TMesample was obtained frcrn rne Wilmoth050232 well on 12/10/2019 This wells one of thetwelve new wells drlledat thsfac lity.Add0lonelly,the sample was obtained after all thewel6 etth s focally ben production As a result,the perinitwill not require initial teazngin ?order o obtain astespecfesample 100200ld be noted that samplencudes sample probe temperature and peosuen con]uctonwth gaugePasre and temperature.According to lab information,rho sample probe temperature and plessure are obtained using lab equipment&Meg the sampling p c s.Them.to aca expected to be core accurate comparedco...p age values and re anceptablefor use in thesmulatio to establshslte spec fe emission factors 3 Please reference the APEN submitted en 01/00/130011list of thetwelvenw wells at the fcity The wets associated with Ohm..battery were Bantu'ed between August and...Tiber 200 and began production n October 2010.Ali the wells et this fa R/produce-Porn the Niobrara formatter. 4.The permit will not containmtalo penodc opaCry testing forthe enclosed comb,.dr(s)becaus_the O&M pin approved fa:the...co requires weeOev beer ;otroiVotn;n,40 the enclosed combustor(s) S.Emission factors for ethylbenzene and?,2,4TMP will not be ncluded nth peimt because-emissions re below APP reporting thresholds b0 ib/year!. 6.The operator provided hefollowhg information regarding the 300 bbl 10 control tent Jigged on thetacltydjagr m e/fie vesseton the pa,.rlryd:ogttlr labeled 3000740000700)Tonaknock., • rank forth,facility's/oe/00t1are.Vapors from truck loodour ate first routed to its rank,and thentotn fIcrededwated to control!,l dare:orttystFes.Any em010 cssoclaredwrthshis tank are :accounted far by the loadoutentissan not normal operation for ANY c d a h tar,In the umk ly event llgodcondensateorurs i0h theta.,either from thecojdensrng fvapors or the flooding afthe tank tuck vapo tl.due ro overjrtl e,thelryurd is untnethatelytransfer from the knocko onk to the coode mate storoyelpn0s.Th s Information indicates any potential sons associated with this vessel are appropriately accounted for in the application. • 7,R throughput lime is owlud0/5 the permit for pilot combustion Emission factors and alcul.on methods for Not lght combustion emissions are also inducted in the otesto permit holder.This '' 'inforrnabons included In the permit because pilot light emissions contribute to the overall emissions from this source Additionally it is important5oinclude this nforms becausethroug outtrack:e • andemsson calculation methods aredif0renithan those used to estimate emsions based on the condensate throughput.-Mrs clarity is important F urately quantifymg actual em sonnet this -p, • facility. B,According to the applcatian,'The hydrecarbonliquid flows toe surge vessel which further sepwateshe fluid phase The hydrocarbon Weed then flowsto a third party pipeline tobesold we a Lease Abtomat'CCustody Transfer(IACT)unit.Attmes when the gevesseis not ope tionalnthe condensate flows totwelve(12(538 661 condensate storage vesses.Thetnk vapors are sent to the enclosed combustors..Based on the facllydesgn,emissions occur when the hydrocarbon!igod is sent to the storage vessels rather than the surge ves ek and when the surge vessel VRU is down It was `determined that titrage vessels and surge vessel do not meet the APEN grouping requiemcts and must beper oted separately.This determinaton was made fora couple reasons First of which is /that thesurge vessel and storagevesseb are two distinct emitting units that have 4,reran control scenarios and distinct throughput values.Further,the regulatory appliabity for the storage vessels s disinctly different f that of the surge vessel.The surge vessel sot class fied oi 40000das a storage vessel and would therefore.not be regulated assuch under NSPS Kb,NSPS 0000/00000 nr Regulation 7,Instead,the surge vessel would be classdleds a separator for Regulation J.requirements.This permit only addresses thefhroughput routed tothe storage vessels resulting sslons Based on the facility desception and discussions tth:he operator,the hydrocarbon lewd is sent directly tothes•orpeese P during surge vessel and LACTdowntme:The hydrocarbon liocd' is ever routed to the surge vessel prior to bang routed t h storage vessels The operatorMdlCated that the surge vessel condensate throughput and condensate throughput routeddrecty to the storogevessee are d s[net and tracked separately. • 9 The operator indicated-that their SCADAsystemdsttectl/measures the volume of hydrocarbon liquid sent to either the surge vessel o the storage vessels.As a result the hydrocarbon liquid throughput for"the surge vessel and storagevessels can be determined'ndepontleutly and accurately 10ln the event the rge vessels not operatonat and/or 0,olACr unit is not available,the operator n401'd that the hydrocarbon Wand from the millet separatorsh routed directly to thert0age vessels.Due.M the faclrtydesign,the srtespeofie sample used to develop:emission factors and estimateemssio sdeemed accepts be because itwsteken from the outlet of the heated separator for the Wilmoth E 5A-232well..Since the sample was taken from the outlet of the separator that sends liquid directly to the storage vessels,n,ial sampling Is not required in the item. 11.The operator provided a copy of the eNO5 that was submitted electronically to the Division forth, 03/26/0 I,the dit1n regtrng submittal eNoticeof startup for this source upon issuance ofthepemt was zou.rc en zo As a. removed from me aerate 11.This source is not soiled to the measurement system'pomp:mean 0 Regulation 0 Part Caen-don C.4 bet.,the oragevess e were constructed before 05/01/2020. 15.The opera tot was Needed with a draft pent and APN red 0e to rewew anal to pubiccemnni The opera., iewved both documents and expressed they had nocommets. .. _. - .... _ vc3td✓"3ko-`h'Va-'Cwwik 2`ws'�.1*kvmz�:ME.•` - Section 09-Inventory See Lodine and EmNsions Factors Uncontrolled Emission: AIRS Point it Process It SOO Code Pollutant Factor Control%Units « --« .^ 01 A Ry p.4« f K ecii0110.7~Ml t' "≥A ^w7 1y„+j FM10 6/1,000 gallons condensate throughput PM2.5 _ 6/1,000 gallons condensatethroughput NOx 1/1,000 gallons condensate throughput V01 6/1,000 gallons condensate throughput CO b/1,000 gallons condensate throughput Benzene _I b/1,050 gallons condensate throughput Toluene - 1/1,000 gallons Condensatethroughput Ethylbenzene .- b/1,000 gallons condensate throughput Xylene 6/4000 gallons condensate throughput n-Hexane 6/1,000 gallons condensate throughput 224 MAP - 6/1,000 gallons condensate throughput 3 of4 C:\Users\hslaught\Desktop\123AOC8\2OWE0192.6P1 Condensate Tank Regulatory Analysh Worksheet The regulatory requirements below are determined based on requested emissions. ATTAINMENT 2.Are unmannered actual analov train anyone. I re from Ire Irelvidualsource greaennanx PY(Regulaton3,Pre A,xaton ova)) m date(severe date)pnor to12/3n,002 and not modified Is anrere and Senn,faaaatowlgtkdance on grandfather appocanfinm) 0 Are real fary unamrdd vac amnions OTPY orco anrsslmsg tar tmn.TH(Regulation S.Part,Senn,o.3)? NONATrellrellnre 1.Are uncontrolled y anon pollutants from this Individual renter tan 1TPY l,eeulartenn PartA,seaton otaR tieRN.retireeR gums.AM,en to the tint q tun E.Is Me consrerefon date w e))od 12/sono0 TP vo0x nee and sa a- gu nce a naratnerapp ca tY1) � 3.Ares halt, o e sa greater anx g erthans r al ma gr taxman la Inn e, ton.azl) ne.. Sown q perms d tunsTPv rvoa rut ono eat sea- rata wresa as v c • n ace n[ne2 and non,natural gas rom?14/22axen or natrle lip non) y y b - inmcxd mah YYP n Pmintsum ry g an anon attatnmem aeu or It tmenanceam) rntnue Veu na i,natcad ores I nmemstar [eProleatsummerya k [an w -on operation', ua asa asa r I rounave c t I ea IFe ma snret n- getan newel[) x Snare„nbtaa BerereMents forrereorelon Control Egwpment-Prenxenmknkage colorado Rseulalon 1.Is this >5v�a malhe a o8reozoneentre area or are non.nonatdnment are or analnmenvmatn[ennaearn) I - tt dmety atammantaama on the2#I2d4 ammaryanm. 2. tankocateda.a natural 4:nepam? i eTnkts norsablea o,egu attonr orlonNB tauM1ave wtdfa gryrypempmfea sgmm.rysMa, a Does t sstura .(g2 strenreonsta hinederesslorts and ova uncontrolled actual eressIonsgmatenhan or equal Ire Inns peryearvocr1.Is thls rvR sorted all and ., Project s 20,,,2 54,16 2.Is Ihis lank re an gas von p ualonopaallon, production hdll[>t.natual eascomprssorsaNen arnx g p s gpl nr PSG i have lnalatdraalayrype on mu,ummry condensate 4.Are uncontrolled actuallm adnkeq n ens4 ynfwc. Yes"au96C',muaax ublaat maaof Regal m>,seasons xvll.,ae 0o to then question m�rr son.mm.s real PrEquipment and Prevealonof Emisslom section Xv ca cements s ooearnemden all onY'stab ad•tgaarr '<I fseurceissubect mall provsons of Regulation>saton xn sume.,ons B.c s.ruon xvU.ex-Capture ana Monitoring ro,xeageTanks audwuhpo-Pollution Control Equlpmnt • hm.o tea imi rnx ens, 2.Dore reelm design quaal(<nm tea.,....soagannk,s nor question rvspsrcb. Qaateveseaa. m'(-xa By ua condensate p�ead,or pantoauatoerranarera=dndmen.x2xm tie 4.Donne lace menthe sloragetare orstuadrs reconstructed,S.Was condensate nor h:eenn f onagau enR,pOA).rvreP>umre�s,u)na 112, oe,the atorare.esse stores'Volatile organIlgad(voy�'aa defined In 60.1111,7 xA 444 x. ores Pans ps)an re(Bo 06(218]).3 6.The,ngng m''/02„p andantes a Mire mgrp ass Pa(20. 022((4 The dreg, airy, he[re BBL]but m'I'ss0 BBL)and stores Ilnindwth a maginurn Inn vapereresure Instan 25,0 kpal00.u0b(b11r 7.one,the a.storage _ 01 m:(-s cont. � with, Im roan a lard, S 88 ia1 'rye To 7S her Betlbut etas than 151 m'rere DUI and store a in re2 a maximum teevre press g enhan rq abate.:4anx).0 Ina? • 6�.a�.w. AOaPa Parton Soren-n.00/00.3,standard,of Par,armoire fnr nude oil and Natural oar production Tr...ohnana o,anmdan linty In Me soon and swing sere..rndna rv) limes 020 rveaa 2.Was.this condensate d(se segment, between q re,x 1,) sabred Nses 0000-oo mtuen q [ton to continue dem,mmalon dxsns 0000a applIcrellIty. ssd=o s d(see 0421,her re[embata,x0xs) t 5.Does thls em,as n ma uall[o sr a nk�:not suoWea xsps 0000,. condensate stonge nese,me 0/5meet -aoa asa sa3mr rvA eves 1 nw edm amragevassen neocgn Paned su6wrt KdorgOe,a P.ns3 suhwn HH) NA a ,,n., Now ublett 000010000e due to emNoory above:ens pr year vocon. pp bilnvdeterminadonaam,itrhouldeomrin uht.am NSPs oo/ono par ens¢5(.1121/eo.510alellxl.v of P ml.l voc.mmmmdrop below e tom par 1884) tlmv e konxaueroawvelnalatdmasoureecategory en The Project a.Abolinythat process Vera 24118n.v rm w 4'(20.122(al(211;oR b. natural 6.pf mine polartwMrh wmal gad nmrnhe natural&as trans...anaamaee sous category or is dewarea to a real end mei(s3.76014311r 2.Is located al of malodor HAW 4414.W..4Ia..setae nkls not subject 214er HH Theresa no WC!HHIeq rmenu(2,(22b al area:rarer: 3. mean.definition der'�roer 4 vinkm a6ep�ei wmnepor - - en xn tarti s.o thread ssubkatmmnne reeuvemenn redrew.Me nunder.O as Part.,subpart Kb 2(201,400441 MA .;t`7 Subpart,Gamin pronslons per ndards sq(4,2,2453 Control Standards 453 463.77,1-PemrdkeePing , . g53.ns-Rapbning Mcirevlew8rg d02.Nla,onrdoeen pply oatnetank,rin222482.mmmem.rea.140.4880 meam0wnmteaytanre,Pw RACTrapufr memo. Disclaimer sststs operators lvRn del4Trdning applicability of retain rapuimments of the clean Alria..i0 implemennngregu2/0482 and AV Quality Control 414402mon regulations T.document.not gulalaon naysis ppN loo ual lacl andrim s:This lelwan If may.,is legally enfrceable_In the event of.na soar, ylarv, regulatbno-aayi QuayCher Ia,C mmossionragranom rent andio nolhelan uag!ceeble-InlneeveetW...oar,be"Then e use Orion-mandatn.ory s.as. .i e.,f Ore rman Ab Aq,:im'can.•iing and Ad Quay Con olthe4,44ulew will..." a.distaibac aches end."ma ant,gl/btlI9140APWmty l.am:tineaom regulations. 024and4ie8064042210 neatlbaascnna controlling rew+�amanh...-112 fern.astne cleannAr is antl Ad/2uallly Control Commission regulations,but this dxumenl eresnol ealebd'eh.Rely bin Mgraluiremmh Inandolilsal{. • COLORADO DEPARTMENT OF PUBLIC HEALTH.AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY • Company Name POC Energy,Inc. County AIRS ID 123 History File Edit Date 7/8/2020 Plant AIRS ID A0C8 Ozone Status Non-Attainment Facility Name Wilmoth 5 Sec HZ EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H25 SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0,0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total • ,_008 GP1Q _. .. _ �_- _.. ..._.. ..._... - 0.Q 0.0.This point is linelevant as the sources covered by it.... have afready been permitted aid covered under p0infs 001.0117&000,This point wilt net toe prvtsSSet.1. XA Twelve(12)0.75 MMBtu/hr Burners 0.3 0.3 0.0 4.3 0.1 3.6 0.0 0.3 0.3 0.0 4.3 0.1 3.6 0.0 Insignificant Source XA Fugitives 0.3 0.0 0.3 0.0 Insignificant Source XA Produced water storage vessels 0.1 0.0_ 0.1 0.0 Insignificant Source XA Sandtrap drain tank 0.5 0.0 0.5 0.0 Insignificant Source FACILITY TOTAL 1.1 1.1 0.0 0.0 99.6 434.1 0.3 137.0 14.4 1.1 1.1 0.0 0.0 14.5 36.1 0.3 23.7 2.7 VOC:Syn Minor(PSD,NANSR and OP) NOx:Syn Minor(NANSR and OP) CO:Syn Minor(OP) HAPS:True Minor HH:Area source-no affected sources 7777:Area source Permitted Facility Total 0.7 0.7 0.0 0.0 95.3 433.3 0.0 133.4 14.4 0.7 0.7 0.0 0.0 10.2 35.4 0.0 20.1 2.7 Excludes units exempt from permits/APENs (A)Change in Permitted Emissions 0.7 0.7 0.0 0.0 10.2 35.4 0.0 20.1 Modeling not required based on A change in emissions.Pubcom is required b/c new syn minor limits are being established and the change in VOC emissions is greater than 25 tpy. Total VOC Facility Emissions(point and fugitive) 36.4 Facility is eligible for GP02 because<90 icy(CO) and<45 tpy(VOC&Nog) (A)Change in Total Permitted VOC emissions(point and fugitive) 35.4 Project emissions greater than 25 tpy VOC Note 1 Note 2 Page 1 of 2 Printed 7/22/2020 COLORADO DEPARTMENT OF PUBLIC HEAL THANI)ENVIRONMENT AIR POLLU ION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name PDC Energy,Inc. • County AIRS ID 123 Plant AIRS ID A0C8 Facility Name Wiimoth 5 Sec HZ • Emissions-uncontrolled(lbs per year POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL IVY) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0192 Twelve(12)538 bbi fixed roof 1751 1538 43 572 11661 46 7.8 condensate storage vessels. 002 GP07 Hydrocarbon Loadout 113.5 984.8 0.5 003 GP02 SI RICE Caterpillar G3306NA,45R8, 770 31 4 29.5 17.6 34 5 0.4 137 HP(site rated),SN:R6002338 004 GP02 SI RICE Caterpillar U3306NA,4SRB, 770 31.4 29.6 17 8 34.5 0.4 137 HP(site rated),SN:66X09234 005 GP02 SI RICE Caterpillar G3306NA,4SRB, 770 31.4 29.8 1-8 34.5 0.4 137 HP(site rated),SN:G6X09289 006 GP02 SI RICE Caterpillar G3306TA,4565, 980.1 45.6 43.2 26 50 3 0.6 203 HP,SN:66503153 007 GP02 SI RICE Cummins G855,4SRB,178 HP 275.5 37.5 ,15.3 211 r5I'1 0.2 (site rated),SN:99800379 008._ GP10 0.0 009 20WE0602 Natural gas flaring from one(1)surge 876 769 '?5 286 6831 '7, 3.9 vessel during VRU downtime XA Twelve(12)0.75 MMBtu/hr Bumers 0.0 XA Fugitives 11.5 11.2 10.8 10.9 12.; 0.0 . XA Produced water storage vessels 12 3 12.4 0.3 2.0. 42 0.0 XA Sandtrap drain tank 5 6 20.2 0.0 TOTAL(tpy) 1.8 0.1 0.1 1.4 1.2 0.0 0.4 9.3 0.1 0.0 0.0 0.0 14.4 "Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text uncontrolled emissions o de minimus • Emissions with controls(Ibs per year) POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H25 TOTALttp11 Previeaa FACILITY TOTAL . 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 20WE0192 Twelve(12)538 bbl fixed roof 88 77 3 29 583 3 0.4 condensate storage vessels 002 GP07 Hydrocarbon Loadout 5 7 49.2 0.0 003 GP02 SI RICE Caterpillar G3306NA,4SRB, 743.4 31 4 2516 17.8 34 5 0.4 137 HP(site rated),SN:R6502338 ' 004 GP02 SI RICE Caterpillar G3306NA,4SRB, 743.4 _31.4 29.6 17.8 34 5 0.4 137 HP(site rated),SN:66X09234 005 GP02 SI RICE Caterpillar G3306NA,4SRB, 743.4 31.4 2_6 1;8 34.5 0.4 137 HP(site rated),SN:G6X09289 006 GP02 SI RICE Caterpillar G3306TA,4SRB, 940.9 459 43.2 26 7-, 0.6 203 HP,SN:R6S03153 007 GP02 SI RICE Cummins G555,4668.178 HP 275.5 37.5 35.3 21 3 dl.1 0.2 (site rated),SN:99800379 008 GP10 0.0 009 20WE0602 Natural gas flaring from one(1)surge 44 39 1 15 292 5 0.2 • vessel during VRU downtime XA Twelve(12)0.75 MMetu/hr Burners 0.0 XA Fugitives 11.2 112 10.8 10.9 12.7 0.0 XA Produced water storage vessels 12.3 12.4, 03 2.6 4.2 0.0 , XA Sandtrap drain tank 5.6 26.2 0.0 TOTAL iltpy)' -- 1.7 0.1 0.1 0.1 0.1 0.0 0.0 0.5 0.1 0.0 0.0 0.0 2.7 • 2 123A0C11 7/22/211211 Colorado Air Permkting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package U: 433152 Received Date: 716/2020 Review Start Date: 7/7/2020 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section Township Range County AIRS ID: 123 NWNW 5 4N 64 Plant AIRS ID: ADC8 Facility Name: Wilmoth 5 Sec HZ Physical Address/Location: .. _ _ .r.:ship 4N R County: Weld County Type of Facility: ':Exploration&Production Well Pad What industry segment:Oil&Natural Gas Production&Processing - - Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRS Point tt Permit It (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Control? APCD has already II Required? Action Remarks assigned) assigned) Permit Initial. 009 Separator Venting Surge Vessel Yes 20WE0602 1 Yes Issuance Section 03-Description of Project PDC Energy,Inc.(PDC)is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area. With this application,the operator is requesting permit coverage for a surge vessel,condensate storage vessels,hydrocarbon liquid loadout and engines.The hydrocarbon liquid loadout and engines are requesting general permit coverage.This analysis only evaluates the surge vessel. This source is APEN.required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Sectionll.63.a.j.Additionally,the source Is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy(CO AQCC Regulation 3,Part B,Section II.D.2.a.). Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements,and the change in VOC emissions as a result of this project is greater than 25 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air impact Analysis Requiremer Was a quantitative modeling analysis required? No - If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration IPSO) ❑ O ❑ I] ❑ ❑ Title V Operating Permits[OP) ❑ LI ❑' ❑O ❑ OOO Non-Attainment New Source Review(NANSR) (] O Is this stationary source a major source? No If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) OOOOOO Title V Operating Permits 1OP) OOOOOOOO Non-Attainment New Source Review(NANSR) O ❑ Separator Venting Emissions Inventory Se.don 01-Administrative Information 'Facility Alfls ID: 123 AOCS .009 - County Plant Point Section 02-Equipment Description Details Detailed Emissions Unit Description: Natural gas fl ing from one O)surge vessel during vapor recovery unit(VRU)downtime. Enclosed Combustor(s) Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency% 95 Limited Process Parameter Dq W,T,4 uuErLrwd ,, ,.y Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 75,777::Barrels(bbl)per Hear Requested Permit LimitThroughput= 90,933 Barrels(bbl)per year Requested Monthly Throughput= .,_s.2 Barrels(bbl)per month Potential to Emit(PIE)Throughput= _167 Barrels(bbl)per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 7418.7.Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 34.2 scf/bbl Control Device I Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Bto/scf Section 04-Emissions Factors&Methodologies - Description Liquid produced by the twelve(12)welts flows to twelve(12)inlet three-phase separators.The liquid from the three-phase separators is then routed to a surge vessel which further separates the fluid phase.The hydrocarbon liquid from the surge vessel then flaws to a third party pipeline to be sold via a lease Automatic Custody Transfor(LACE).unit.During VRU downtime,surge vessel emissions are routed to the storage vessel. vapor manifold and controlled with the condensate storage vessel'emissions.Emission factors for this sourcewere calculated using a site specific pressurized liquid sample obtained from the outlet of the inlet three-phase. separator for the Wiimoth E 5A-232 well on 12/10/2019 in conlunction.with ProMax.The sample temperature and pressure are 114°F and 31.3 ps g respectively.As discussed in Section 08,the emission factors used for this source reflect the emission factors developed for the condensate storage vessels and constitute a conservative estimate of emissions.Values-from the ProMax simulation are shown in the table below. ProMax Flow Rate 227,33200 bbl/year Pollutant Flash Gas(lb/hr) W&B Gas(lb/hr) Total Waste Gas Rate Source (lb/hr) VOC 56.14153251 18.6826484 ProMax Benzene 0.205905 0.0439265 '. ProMax Toluene 0.178805 0.0406108 ProMax Ethylbenzene 0.00406813 "0.00121251 'ProMax Hylenes 0.0614845 0.0201208 ProMax n-Hexane 1.26136 I 0.402511 ProMax 2,2,4-TMP 0.00456713 J 0.00154601 -1 ProMax Emission Factors Separator Venting Uncontrolled Controlled _ (16/661) (lb/bbl) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) VOC ..., ProMax Benzene ... '4,, ProM - Toluene ProMax - Ethylbenzene - Prato x %ylene 4. ProMax n-Hexane r ProMax 224 TMP ._ } ProMax Primary Control Device Uncontrolled Uncontrolled Pollutant (ib/MMBtu) lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 0.0075 -AF-42Tabla'1.4-2(PMOO/PM.2.5) PM2.5 0.0075 AP-42 Table 1.42(PM10/Pfv1.2.3) SOr 00006 <-1` Fes.' AP-42 Table 1.4-2(Sox) NOx 0.1380 'MK(Flare Emissions Guidance(NO() CO 0.2755 TNRCCFlare Emissions Guidance(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 0 PM2.5 [0 i, SOx NOx 00 VOC 0.000B u, CO I 4.O.^. Section OS-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tans/year) (tons/year) (tons/year) (tons/yea() Ps/month) PM10 _. „0,3 PM2.5 3... 4 SOx _. - ,_ _ __ NOx ,3_ VOC ..3.743 ..i CO 0.862 0.€07 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) Ilbs/year) (Ibs/years Ohs/Year) fibs/year) Benzene 172,__ .. ,7, ,3'.37 Toluene 700.30 640.70 3.7.. 02.- Ethylbenzene 1_31 17.76 4.19 , )Lylene 285-3`. '_33.33 1191 14» n-Henna 5820.72 46659.43 242.52 0241.22 231.x1 224TMP 22,07 19.02 0,55 22.12 __z 2 of 4 C\Users\hsiaught\Desktop\123A008\20W E0602.CP1 Separator Venting Emissions inventory Section o6-Regulatory Summary Analysis Regulation 3,Parts A,B __.>__ -- Regulation7,PartD,Sectienll.B,F Spate o telgeof Xannionon _._ Regulation 7,Part D.Section II.B.2.e (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements .'r0.n urn } /,e np rue.: K.,... ..... ,rm: z ., r r-'L T: v' .stay cry-' .:-.>.v:.;:..>.. ::rot„ :.. -r .:...:.::> s i ..<./ ace s.v eMiliri ir s000z,ib rla xl n t w ,a, Ye''A_4«rxirre„s>..�':�7 x',a. 'y mE'>A LkaEaiv',."r' ,� ,w., z Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based one pressurized liquid sample(Sampled upstream attire., equipment covered under this AIRS ID)and process simulation to estimate emissions? 'This sample should have been collected within one year of the application receiveddate.However,if the facil'Ry has not been modified(e.g., no new wells brought on-line);then it may be appropriate to use an older site-specific sample. If no,the permit will contain an'Initial Compliance'testing requirement collect a site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established with this applicator. Does the company request a control deice efficiency greater than 95%for a flare or combustion deuces If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes 1:The site specificsample used to estabiishemisslonsfactors forthis sourcewas obtained within a year of the application.The sample was obtained from the outlet of thethree-phase seperatorfor W ilmoth E SA-252 well on 12/10/2019. This well is one of thetwelve new wets drilled at this facility.Additionally,the sample was obtained after all the wells at this facility began production and directly upstream of the surgevessel.As a result,the permit will not require initial testing in order to obtain a site specifk sample.It should be noted that the sample includessample probetemperature and pressure in conjunction with gauge pressure andtemperature.According to lab information,the sample probe temperature and pressure are obtained using lab equipment during the sampling process.Thesevatues are expected to be more accurate compered to the gaugevalues and are acceptablefor use in the simulationtoesteblish site specific. Isslonfaaom. • '-2,Please referencethe condensate storagevessel APENaubmitted on 12/51/19 fora list of thetwelve new wells at this facility.The wells associated with this facility were fractured betweenAugun and September 2019 and began production in October 2019.All the wells at this facility produce from the Niobrara formation. • lime permit will not contain initial or periodic opacity testing for the enclosed combustors)becausethe 0&M plan approved forthis source requires weekly visible emissionseb≤ervations of the enclosed combustor(s). 4.Emission factors for ethylbenzene end 2,2,4-TMP will not be included inthe permit becauseemissions are below APEN reporting thresholds(I.e.0250 lb/year). 5.During VFW downtime,the surge vessel is control led by the same enclosed combustors used to control storegevessel emissions.According to engineering guidance,the pilot lfghtemissions are grouped with the highest emitting source .. controlled by the common control device.In this case,the storage vessels are the highest emitting source.As a result pilot lightemaslons ere accountedfor with the storagevessels(20WE0192)and not this analysis. According to engineer guidance,thetotal combustion emissions(i.e.NOx and CO)from all the sources controlled bye common control deviceshould be added together forevaluation against APEN reporting thresholds.In this case,NOx and CO emissions from the surge vessel are below APENthresholds.However,total NOx and CO emissions£rom all the sources controlled by the enclosed combustors(i.e.storagevessels and surge vessel)are above APES reporting ≥thresholds.As result all the sources controlled by the common control device will include limits on both NOx and CO emissions. - - 7.In order..calculate surge vessel emissions,the operator is using the emission factors established forthe condensate storage vessels.Theso emission factors were deemed acceptable and conservative forthe following reasons:(i)The operator indicated that the surge vessel IS not used to store condensate priortosendingthe llquidtothe tACT.Thls is supported by the informationthet the condensate is muted directlyo the storage vessels in the event that the LACE is not ayailable.As a result,the emissions fromthe surgevessel do not include working and breathing emissions in actual operation.The emission factors developed forthe wndensatestoragevessels do include working and breathing emissions.Iii)Further,the operator irdicatedthet the surge v sel usually operates between 4-6 psig,whereasthe sxoregevessels operate at essentially ambient pressure(0 psis).The ProMax simulation models flash emissionsthat occur " ' from 43,8 Asia to 12,5 paid.Since thesurge vessel operates at a higher pressure,the flash emissionsare likely less than what was modeledb'y the ProMax simulation forthe storagevessels. "e.According to the application,'The hydrocarbon liquid fowsto a surge vessel,which fhathersepaatesthe fluid phase.Tho hydrocarbon liquid then flows toe third party pipelfneto besold via e Lease AutomaticCunody Transfer(LAM') unit At times when the surge vessel is not operational,the condensateflows totwelvo(12)538 bbl condensate storage vessels.Theterk vapors are sent to the enclosed combustors,"Based on the faeility design,emissivnsoccur when the :f hydrocarbon liquid Is sent to thestoryoe vessels rather than the surge vessels and when the surgevessel VRU is down.lt was determinedthat the storage vassals and surgevessel do nOt meet the APEN grouping requirements and must be permitted separately,Thisdetermination was made fora couple reasons.First of which is that the surgevessel and storegevessels are two distinct emitting units that have different control scenarios and dlstinctthroughput values.Further, the regulatory epplicabilltyforthe storage vessels is distinctly different from that of ihesurge vessel.The surgevessel is not classified or defined as a stoagevessel and would thereforenot be regulatedas such under NSPS Kb,SOPS 0000/0000a or Regulation 7.Instead,the surge vessel would be classified as a separamrfor Regulation].requirements.This permit only addresses the throughput routed to the surge vessel and the resulting emissions.Since emissions only result during VRU downtime,the-permit will contain a VRU downtimetacking condition. 9.The operator indicated that theirSCADA system distinctly measures the volume of hydrocarbon Boob sentto eitherihe surge vessel or the storage vassals.As a result,the hydrocarbon liquid throughput forthe surge vessel and storage vessels can be determined independently and accurately, , Traditionally,separatorsources-wtih emissions greater than 100 tpy are required to use a flow meter and gasthroughput`or ongoing compliance demonstrations.In this case,the facility is designed such that the emissionsfrom the surge vessel are tedto the condensate storage vessel vapor manifold and are controlled in conjunction with the condensate storage vessel emissions.Based on the facility design,retroactive installation of a flow mewls not feasible and ',Would not provide a meadsofdifferentatingstoragevessel emissions from surge vessel emissions.Addltfonelly,the operator is being overly conservative in calculating emissions since they are singthe emission factors developed forthe storage vessels.Finally,the operator already has a means of accurately quantifying the liquidthraughput forthe surge vessel.Based on these reasons,it was determined that liquidthroughput was a viable-option for demonstrating ongoing compllance. It.The operator was provided with a draft permit and APEN redlineta review prior to peblicdomment The operator reviewed both documents provided comments on the draft permit.The comment provided and Division response areas follows:(i}Comment:'I've reviewed the draft permits and APES redlines,and only haveone comment.Can the NOS permit condition in permit 20W E0602 please be removed?Botha paper copy and a digital NOS have been submitted for -this source,withthe digttal submittal receipt attached for your reference.Response:Thank you for providing a copy of the completed eNOS.5ince a complete eN05 has been submitted,the NOS condition will be removed from the permit as requested. - -Section 09-5CC Coding and Emissions Factors(For Inventory Use Only) AIRS Point tt Process f1 5CC Code Pollutant Uncontrolled Emissions Factor Control% Units 009 01 - - - PM10 n.of :arr;ve Oars=t. PM2.5 _o .: lf;ii3"'0 bare. Spa 0,0 G. 'uyl7GO6z-r:Is NOx __,- _ Val 3ar<>?b VOC .C.`P.3 __ 1AOOc_.,el> CO _. -r R{trnn 4zrra=z Benzene 9,4 theTAUP to,en Toluene P.5 e Ethylben e 't.2 ___..,n 3.1 ._ wlec';Sot,€j 14, xylene eta n-Hexane s4,1 95 'h 1ASJ Garr h • 224TMP ..o =x/iCiU bar:xl≤ • • • • • • 3 of 4 C:\Users\hsl aught\Desktop\123AOC8\20W E0602.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and 8-APEN and Permit Requirements Sou.,vs to tn4r tv"t•xt llttatanre,,c Ae 53 - ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? 2. Are total facility uncontrolled VOC emissions greater than 5TPY,N0x greater than 50 TPY or C0 emissions greater than 10TPY(Regulation 3,Part B,Section 11.D.3)? rsmr nave tvdtc,ated dm,sta..r to to saa ISo A¢tetnm+:xrr Ar a NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section II.D.1.a)? Yes '4 Source Requires an APEN.Go to the next question 2. Are total facility uncontrolled VOC emissions from the greater than 2TPY,NOx greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section ll.D.2(? Ye5...,.,(Source Requires permit IS:,s1rre:e„•sisareer.;a pnrmr[ Colorado Regulation 7,Part 0,Section II 1. Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? y¢sr.Au;;'?ISqurce is subject,go to next question �Ysi .P^ni su231t"Ct{�,FEe+.3v1,cl.farn 5,Patti I..., ii ii.?,4 Section 11.8.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section II Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section) a. Is this separator controlledby a back-up or alt rnate comb tt ndevice(t not the primary control device)that is not enclosed? y• I 'Fn4¢esl,{02t)t,t,I Y'$,tdr .(.' .flirt,c it 4 " ...,tri llei i r.Url I,Nn'tIt, ES tit,ir It,.4., Section II.B.2.e—Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act,,its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control, The use of non-mandatory language such as"recommend,""may,""should," and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must"and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. zoo l, DPH Condensate Storage Tank(s) APEDC r Form APCD-205 CO Air Pollutant Emission Notice(APEN)and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates.An application with missing information may be determined incomplete and may be returned or result in longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal, This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category, there may be a more specific APEN available for your source(e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading,etc.). In addition, the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.colorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.). See Regulation No. 3, Part A, II.C.for revised APEN requirements. Permit Number: Z t Yv ei ,C 2 MRS ID Number: I23 'AQ>cB f col [Leave blank unless APCD has already assigned a permit u and AIRS ID] Section 1 -Administrative Information Company Name': PDC Energy, Inc. Site Name: Wilmoth 5 Sec HZ Site Location Site Location: NWNW Sec 5 T4N R64W County: Weld NAICS or SIC Code: 1311 Mailing Address: (Maude Zip ) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Contact Person: Jack Starr Phone Number: (303) 860-5800 E-Mail Address2: Jack.Starr@pdce.com 'the the full,legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.My changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices will be issued by the APCD via e-mail to the address provided. qii+CID 2-- • COLORADO Form APCD-205 Condensate Storage Tanktsl APEN Revision 7/2018 1 Iilek.V """` Permit Number: AIRS ID Number: 1, /,due / OO% [Lease blank unless APCD has already assigned a permit a and AIRS It}) Section 2- Requested Action 0 NEW permit OR newly-reported emission source O Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GP08 if General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- i ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownership' O Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAi.PERMIT AcnoNs- APEN submittal for permit exempt/grandfathered source ❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional info&Notes: Initial permit request for condensate storage tanks at a new facility 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 'For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 -General Information General description of equipment and purpose: Condensate Storage Tanks Company equipment Identification No. (optional): TK-1 For existing sources, operation began on: 10/03/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration Et Production(E&P)site O Midstream or Downstream(non EiFtP)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Is the actual annual average hydrocarbon liquid throughput z 500 bbl/day? 0 Yes O No If"yes", identify the stock tank gas-to-oil ratio: 0.006083 m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) .0 Yes CI805 series rules?If so, submit Form APCD-105. No Are you requesting z 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual 0 Yes ❑ No emissions a 6 ton/yr(per storage tank)? Il coio��aa Form APCD-205 Condensate Storage Tankisi APEN -Revision 7/2018 2 I [a` Permit Number: ti O C `9 AIRS ID Number: 1? /44) OO1 (Leave blank unless APCD has already assigned a permit a and AIRS ID] Section 4 - Storage Tank(s) information Actual Annual Amount Requested Annual Permit Limits (bbl/year) (bbl/year) Condensate Throughput: . P.l7;ZZi- tc4,V5 5 49w177J'E 04.g.t40 From what year is the actual annual(amount? Projected Average API gravity of sales oil: 52.5 degrees RVP of sates oil: 8.0 Tank design: 0 Fixed roof O Internal floating roof O External floating roof • Storage of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) TK-1 12 6,456 10/2018 10/2019 Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only) API Number Name of Well Newly Reported Weil 05 • 123 •45483 Wilmoth E 5A-202 0 • 05 • 123 •45485 Wlmoth E 5A-232 0 05 -123 -45490 Wilmoth E 5A-302 0 05 • 123 -45484 WiImoth E 5A-312 0 05 • 123 -45487 Wilmoth E 5J-232 0 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. 6 The E&P Storage Tank APEN Addendum(Form APCD•212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or tfTM) 40.34576/-104.57952 Operator Stack Discharge Height Above Temp. Flow Rate Velocity ID No. Ground Level(feet) ('F) (ACFM) (ft/sec) N/A Indicate the direction of the stack outlet: (check one) ❑Upward 0 Downward 0 Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size:(check one) ❑Circular Interior stack diameter(Inches): ❑Square/rectangle Interior stack width(Inches): Interior stack depth(inches): ❑Other(describe): co&OR*oo Form APCD-2O5 Condensate Storage Tankisi APEN Revision 7/2018 3 I .•'"" g, .04..C ;CatiC*1/4 %JD'S Of**to Permit Number: LJt .) 4'1L- [Leavee AIRS ID Number: blank unless APCD has already assigned a permit r and AIRS ID[ Section 6-Control Device Information 0 Check this box if no emission control equipment or practices are used to reduce emissions,and skip to the next section. Pollutants Controlled: Vapor Size: Make/Model: O Recovery Unit(VRU): Requested Control Efficiency: % VRU Downtime or Bypassed(emissions vented): S Pollutants Controlled: '/QC&HAPS Rating: MMBtu/hr Type: Enclosed combustors ors Make/Model:12 x Cimarron 48",1 x Cimarron 60" ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2,418.73 Btu/scf Constant Pilot Light: 0 Yes 0 No Pilot Burner Rating: 0.018 /AMBtu/hr Description of the closed loop system: ❑ Closed Loop System Pollutants Controlled: ❑ Other: Description: Control Efficiency Requested: % Section 7-Gas/Liquids Separation Technology Information (EftP Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 31.3 psis Describe the separation process between the well and the storage tanks: High/Low Pressure Separator eatOI8ao Form APCD 205 Condensate Storage Tank(s)APEN- Revision 7'2018 4 i Mk' ., . Permit Number: LO LAX.C.)011.- AIRS ID Number: ill, //1/4)(2--)1 CO i (Leave blank unless APCD has tread assigned a perrn;t ir ono AIRS ID Section 8 - Emissions Inventory Information Attach all emissions calculations and emission factor documentation to this APEN form. If multiple emission control methods were identified in Section 6, the following table can be used to state the overall(or combined)control efficiency 01 reduction): Overall Requested Control Pollutant Description of Control Methods) Efficiency (%reduction in emissions) VOC EnOo d Cornbw,or tax NOx CO ' HAPs Endows Carouses. 95% Other: From what year is the following reported actual annual emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)S Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions Emissions Emissions Basis Mfg.etc) (Tons/year) (Tons/year) (Tons/year) (Tons/year) ►4Iwl ?„o*'o.s U'6H 10.93 'L t.%ci 13•+Z '� VOC j.a�'.�b+3 ,t1w5ct .w'-tit 9 NOx 0,SF2.laW4 ib/MMBtu .ec APtl I.\$ l!9,, 1.4 1.4 iI CO c,1x'55j0 t,1 Ib/MMBtu 1'Cfo,/1P L•St- t-SL 'L•gb i.'9e Non-Criteria Reportable Pollutant Emissions Inventory Chemical Emission Factor Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Service(CAS) Uncontrolled Units (AP-42i Emissions Emissions8 Number Basis Mfg.etc) (Pounds/year) (Pounds/year) Benzene _71432 0.0096 lb/bbl ProMax rat*" 1-73 Toluene 108883 0.0085 lb/bbl ProMax iv t. i tif.1 Ethytbenzene 100414 0.0002, lb/bbl ProMax SS•S S ()m) 1.Q (f:i*0 Xylene 1330207 0,0031- Ib/bbl ProMax K-µr4 L5•1g ' n-Hexane 110543 0.0641 lb/bbl ProMax qli} 485.9 2,2,4• 540841 2.51 E-04 lb/bbl ProMax 36 (D--) 1.9 (I0) Trlmethylpentane I 5 Requested values will become permit limitations.Requested limit(s)should consider future growth. Attach condensate liquid laboratory analysis,stack test results,and associated emissions calculations if you are requesting site specific emissions factors according to the guidance in PS Memo 14-03. a Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave blank. • 1r1Gt/w J AC,y 'K c..I % Qpp1 i cp,b o.", . 4 OS olio+az [otO1.FO Form APCD-205 Condensate Storage Tank(s)APEN - Revision 7/2018 5 I °" ""'"` L , Permit Number: ) 0 tall.- MRS ID Number: %-L\ / s/ Col (Leave tsar unless APCD NO already assigned a perm;t•and AIRS ID) Section 9 -Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true,and correct. If this is a registration for coverage under General Permit GP01 or GP08, I further certify that this source is and will be operated in full compliance with each condition of the applicable General Permit. �1� St-. -- Sigáre of Legally Authorized Person(not a vendor or consultant) Date Jack Starr Air Quality Representative Name(print) Title Check the appropriate box to request a copy of the: 0 Draft permit prior to issuance 0 Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years.Submission of a revised APEN is required 30 days prior to expiration of the five-year term,or when a reportable change is made(significant emissions increase, increase production, new equipment,change in fuel type,etc.).See Regulation No. 3, Part A, II.C.for revised APEN requirements. Send this form along with$191.13 and the General Permit For more information or assistance call: registration fee of$312.50,if applicable, to: Small Business Assistance Program Colorado Department of Public Health and Environment (303)692-3175 or(303)692-3148 Air Pollution Control Division APCD-SS-B1 APCD Main Phone Number 4300 Cherry Creek Drive South (303)692-3150 Denver,CO 80246-1530 Make check payable to: Or visit the APCD website at: Colorado Department of Public Health and Environment https://www.cotorado.ttov/cdpbefapcd COi.O1•a00 Form APCD-2O5 Condensate Storage Tanks APEN - Revision 7.2018 6 I ' E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: PDC Energy,Inc, Source Name: Wilmoth 5 Sec HZ Emissions Source AIRS ID2: N/A/ /Z3/,4OC,Flee Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123.45480 Wilmoth E 5K-312 05-123-45489 Wilmoth W 5A-204 05- 123-45481 Wilmoth W 5A-214 05-123-45486 Wilmoth W 5A-304 05-123-45482 Wilmoth W 5A-314 Dig 05-123-45488 Wilmoth W 5A-334 El 05.123-45491 Wilmoth W 5J-234 - - ❑ 0 0 0 0 0 0 0 0 - - ❑ 0 0 0 Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter N/A Form APCD-212 TK-1 Addendum Received 07/06/2020 ...r Gas Air PollVenting APEN - Forutant Emission Notice (APEN) m APCD-211 Da"€ d Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 20WE0602 AIRS ID Number: 123 /A0C8 / 0 0 9 [Leave blank unless APCD has already assigned a permit r and AIRS ID] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Wilmoth 5 Sec HZ Site Location: NWNW Sec 5 T4N R64W Site Location Weld County: NAICS or SIC Code: 1311 Mailing Address:(Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Contact Person: Jack Starr Phone Number: (303) 860-5800 E-Mail Address2: Jack.Starr@pdce.com 1 Use the full, legal company name registered with the Colorado Secretary of State.This is the company name that will appear on all documents issued by the APCD.Any changes will require additional paperwork. 2 Permits,exemption letters, and any processing invoices will be issued by the APCD via e-mail to the address provided. ]COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 1 I air HMittti6En"`aWmok onment Permit Number: 20WE0602 AIRS ID Number: 123 /A0C8/ 009 [Leave blank unless APCD has already assigned a permit#and AIRS ID; Section 2 - Requested Action El NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment ❑ Change company name3 0 Add point to existing permit ❑ Change permit limit 0 Transfer of ownership4 ❑ Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- El Limit Hazardous Air Pollutants (HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info£t Notes: APEN submittal for emissions associated with surge vessel vapor recovery unit(VRU)downtime. Emissions calculated using the condensate storage tank ProMax simulation and emission factors 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Surge vessel VRU downtime emissions Company equipment Identification No. (optional): Surge Vessel For existing sources, operation began on: 1 0/3/2019 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS ❑✓ Yes 0 No nonattainment area? Is this equipment located at a stationary source that is ❑ Yes ❑✓ No considered a Major Source of(HAP) Emissions? Is this equipment subject to Colorado Regulation No. 7, ❑✓ Yes ❑ No Section XVII.G? COLORADO Form APCD-211 - Gas Venting APEN - Revision 12/2019 2 I 'K Permit Number: 20WE0602 AIRS ID Number: 123 iAOC8i 009 [Leave blank unless APCD has already assigned a permit and AIRS iDI Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing ❑ Pneumatic Pump Make: Model: Serial#: Capacity: gal/min ❑ Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event ❑ Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes ❑ No Vent Value: Gas 2 419 BTU/SCF Gas Venting Heating Value: , Process Parameters5: Requested: 3.106 MMSCF/year Actual: 2.588 MMSCF/year -OR- Liquid Throughput Process Parameters5: Requested: 90,933 bbl/year Actual: 755,777 bbl/year • Molecular Weight: 43.2696 VOC (Weight%) 7 4 . 0 4 Benzene (Weight%) 0.25 Vented Gas Toluene (Weight%) 0.22 Properties: Ethylbenzene(Weight%) 0.01 Xylene (Weight%) 0.08 n-Hexane (Weight%) 1.65 2,2,4-Trimethylpentane (Weight%) 0.01 Additional Required Documentation: 0 Attach a representative gas analysis (including BTEX 8 n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis(including BTEX£t n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable,and should consider future process growth. Requested values are required on all APENs,including APEN updates. jecCOLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 3 Redlines per ProMax simulation. (HDS 07/08/2020) Permit Number: 20WE0602 AIRS ID Number: 1 23 /AOC8/ 009 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 5 - Geographical/Stack Information Geographical Coordinates '" (Latitude/Longitude or UTM) 40.34576/-104.57952 ❑✓ Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge Height Operator' Temp. =4 Flow';l Rate Velocity Above Ground Level Stack ID NO: {°F) (ACli4t) :(}ttsec) ,feet) � �, '- _ z Indicate the direction of the stack outlet: (check one) ❑ Upward O Downward O Upward with obstructing raincap ❑ Horizontal ❑ Other (describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other(describe): Section 6 - Control Device Information O Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC & HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model: 12 x Cimarron 48"&1 x Cimarron 60" ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2,419 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating: 0.018 MMBtu/hr Pollutants Controlled: ❑ Other: Description: Requested Control Efficiency: COLORADO Form APCD-211 -Gas Venting APEN - Revision 12/2019 4 I eel � Permit Number: 20WE0602 AIRS ID Number: 123 /A0C8/ 009 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes O No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SO. NO. CO VOC Enclosed Combustors 100% 95% HAPs Enclosed Combustors 100% 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Emission Factor Actual Annual Emissions Requested Annual Permit Emission Limit(s)5, Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (--'i2' Emissions Emissions6 Emissions Emissions Basis r Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NO„ 0.1380 Ib/MMBtu TCEQ N/A 0.43(DM) N/A 0.52(DM) CO 0.2755 lb/MMBtu TCEQ N/A 0.86 N/A 1.03 VOC 2.8833 lb/bbl ProMax 109.24 5.46 131.09 6.55 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable, and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-criteriaEl Yes ❑ No pollutants (e.g. HAP- hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor Actual Annual Emissions Abstract Source Uncontrolled Controlled Chemical Name Uncontrolled Service(CAS) Basis Units (AP-42, Emissions Emissions b Number Mfg.,etc.) fibs/year) (lbs/year) Benzene 71432 0.0096 lb/bbl ProMax 729.50 36.48 Toluene 108883 0.0085 lb/bbl ProMax 640.68 32.03 Ethylbenzene 100414 0.0002 lb/bbl ProMax 17.76(DM) 0.89(DM) Xylene 1330207 0.0031 lb/bbl ProMax 238.29(DM) 11.91(DM) n-Hexane 110543 0.0641 lb/bbl ProMax 4,858.67 242.93 2,2,4-Trimethylpentane 540841 2.51E-04 lb/bbl ProMax 19.02(DM) 0.95(DM) Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 5 I I°""`°"`"` "` ww�n a envf.onmen� Permit Number: 20WE0602 AIRS ID Number: 123 /A0C8/ 009 Section 9 - Applicant Certification I hereby certify that all information contained herein and information submitted with this application is complete, true, and correct. -412212-07-0 Siv�4 ure of Legally Authorized Person(not a vendor or consultant) Date Jack Starr Senior Air Quality Representative Name(print) Title Check the appropriate box to request a copy of the: (]Draft permit prior to issuance El Draft permit prior to public notice (Checking any of these boxes may result in an increased fee and/or processing time) This emission notice is valid for five(5)years. Submission of a revised APEN is required 30 days prior to expiration of the five year term,or when a reportable change is made(significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Send this form along with$191.13 to: For more information or assistance call: Colorado Department of Public Health and Environment Small Business Assistance Program Air Pollution Control Division (303)692-3175 APCD-SS-B1 OR 4300 Cherry Creek Drive South (303)692.3148 Denver, CO 80246-1530 APCD Main Phone Number Make check payable to: (303)692-3150 Colorado Department of Public Health and Environment Hello