HomeMy WebLinkAbout20203733.tiff ��,,X7 COLORADO
o 1 Department of Public RECEIVED
Health&Environment
DEC 0 7 2020
WELD COUNTY
COMMISSIONERS
Weld County - Clerk to the Board
1150O St
PO Box 758
Greeley, CO 80632
December 2, 2020
Dear Sir or Madam:
On December 3, 2020, the Air Pollution Control Division will begin a 30-day public notice period for
SRC Energy, Inc. (now PDC Energy, Inc.) - SRC Wiedeman Pad. A copy of this public notice and the
public comment packet are enclosed.
Thank you for assisting the Division by posting a copy of this public comment packet in your office.
Public copies of these documents are required by Colorado Air Quality Control Commission
regulations. The packet must be available for public inspection for a period of thirty (30) days from
the beginning of the public notice period. Please send any comment regarding this public notice to
the address below.
Colorado Dept. of Public Health &t Environment
APCD-SS-B1
4300 Cherry Creek Drive South
Denver, Colorado 80246-1530
Attention: Public Notice Coordinator
7.oY cow.
4300 Cherry Creek Drive S., Denver,Co 80246-1530 P 303-692-2000 www.colorado.gov/cdphe ,7. o ,6,:
Jared Polls,Governor I Jill Hunsaker Ryan,MPH, Executive Director '..1.
Polo l: c Rev- (,J cc:pi_(rr),HL(Ds/rR)pta(m/ER/cNKrc), 2020-3733
1.2/.2_3/20 OG(sM)
12/►5/20
M.M,1, Air Pollution Control Division
Notice of a Proposed Project or Activity Warranting Public
COPHE
Comment
Website Title: SRC Energy, Inc. - SRC Wiedeman Pad - Weld County
Notice Period Begins: December 3, 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: SRC Energy, Inc.
Facility: SRC Wiedeman Pad
Exploration Et Production Well Pail
NWNE Section 5 T5N R66W
Weld County
The proposed project or activity is as follows: This existing production well pad is requesting to convert
their GP01 and GP07 coverages for their condensate tanks and condensate loadout, respectively, to
individual construction permits. The emissions factors for the condensate storage tanks are being updated
based on site-specific sampling and the source is requesting 98% control efficiency for the enclosed
combustion device.
This facility is a synthetic minor facility for VOC, NOx, CO, n-hexane and total HAPs. Note that this facility
is now owned and operated by PDC Energy, Inc, and not SRC Energy, who submitted the original application.
The Division has determined that this permitting action is subject to public comment per Colorado
Regulation No. 3, Part B, Section III.C due to the following reason(s):
• the source is requesting a federally enforceable limit on the potential to emit in order to avoid other
requirements
The Division has made a preliminary determination of approval of the application.
A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE1020 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.gov/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:
Lauraleigh Lakocy
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South, APCD-SS-B1
Denver, Colorado 80246-1530
Y�y COLORADO
s"-�;r�' Department of Public
1 I Health&Envitonment
C1 -r.Y•M.� COLORADO
• 4 4,/ Air Pollution Control Division
Department of Pab6c Heath&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 1 9WE 1020 Issuance: 1
Date issued:
Issued to: SRC Energy, Inc.
Facility Name: SRC Wiedeman Pad
Plant AIRS ID: 123/9F3E
Physical Location: NWNE SEC 5 T5N R66W
County: Weld County
Description: Well Production Facility
Equipment or activity subject to this permit:
Facility AIRS Emissions Control
Equipment Point Equipment Description Description
ID
TNK 1-10 001 Ten (10) 400 barrel fixed roof storage Enclosed Combustion
vessels used to store condensate Devices
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.Rov/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 14
C <r:» COLORADO
W Air Pollution Control Division
Department of Public Health b Environment
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.)
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. Within one hundred and eighty days (180) of the latter of commencement of operation or
issuance of this permit, the operator must install equipment necessary to monitor control
device pilot light status as described in this permit.
5. 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
6. 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 NOX VOC CO Type
TNK 1-10 001 --- 2.6 26.8 11.5 Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits, for both criteria and hazardous air 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.
7. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. 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.
8. The owner or operator must track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must be
Page 2 of 14
•.; COLORADO
4.0.440 Air Pollution Control Division
DP
Department Department of Public Health Er Emnronment
Dedicated to protecting and improving the hearth and environment of the people of Colorado
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities are defined as any activity or equipment, which emits any amount but
does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3,
Part C. II.E.)
.E.)
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC.
9. 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 Control Device
ID Point Controlled
Emissions from tanks are routed to enclosed
TNK 1-10 001 combustion devices (Make: IES, Model: 96", VOC and HAP
Serial Numbers: 01-07, 01-08, 01-35,`01-36)
PROCESS LIMITATIONS AND RECORDS
10. 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, II.A.4.)
Process Limits
Facility AIRS
Equipment Point Process Process Parameter Annual Limit
ID
TNK 1-10 001 01 Condensate throughput 1,426,640 barrels
02 Combustion of pilot light gas 0.4 MMSCF
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.
11. On a minimum of an hourly basis, the owner or operator shall monitor the control device for
the presence of a pilot light and an operational auto-igniter. These monitoring records shall'
be used to calculate control device downtime. During periods without the presence of a pilot
light and/or an operational auto-igniter, the flow volume from emissions source(s) shall be
assigned a 0% control efficiency. These monitoring records must be maintained for a period
Page 3 of 14
,,,i, COLORADO
�/ Air Pollution Control Division
�ii� Department of Public Heath&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
of five (5) years, and a summary of monthly pilot light downtime and flow volume during pilot
light downtime shall be provided to the division upon request.
STATE AND FEDERAL REGULATORY REQUIREMENTS
12. 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)
13. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
14. 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)
15. 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
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.
16. 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.
17. 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.
Page 4 of 14
r:<r� COLORADO
Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
18. 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 & MAINTENANCE REQUIREMENTS
19. Upon startup of these points, the owner or operator must follow the most recent operating and
maintenance (O&M) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions to
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
20. The owner or operator must complete site specific sampling including a compositional analysis
of the pre-flash pressurized condensate routed to these storage tanks and, if necessary for
emission factor development,a sales oil analysis to determine RVP and API gravity. Testing
must be in accordance with the guidance contained in PS Memo 05-01. Results of testing must
be used to determine site-specific emissions factors for VOC and Hazardous Air Pollutants using
Division approved methods. Results of site-specific sampling and analysis must be submitted to
the Division as part of the self-certification and used to demonstrate compliance with the
emissions factors chosen for this emissions point.
21. The owner or operator must demonstrate compliance with opacity standards, using EPA
Reference Method 22, 40 C.F.R. Part 60, Appendix A, to determine the presence or absence of
visible emissions. "Visible Emissions" means observations of smoke for any period or periods of
duration greater than or equal to one minute in any fifteen-minute period during normal
operation. (Regulation Number 7, Part D, Sections I.C, II.B.2. and II.A.23)
22. The owner or operator must conduct an initial source compliance test to measure the mass
emission rates of the pollutants listed below, demonstrate compliance with the emissions limit
in this permit, and to demonstrate a minimum destruction efficiency of 98%for volatile organic
compounds (VOC). During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (M0) using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Page 5 of 14
r•.<, COLORADO
110 'Neer' Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(M1-Mo)/M1
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Results of the initial compliance tests must be submitted to the Division as part of the self-
certification and must demonstrate compliance with the emissions limits contained within this
permit. If the results of the initial compliance tests do not demonstrate compliance with the
emissions limits contained within this permit or do not demonstrate a minimum destruction
efficiency of 98% for volatile organic compounds (VOC), the owner or operator must submit to
the Division within 60 days, or in a timeframe as agreed to by the Division, a request for
permit modification to address these inaccuracies. (Regulation Number 3, Part B., Section
III.G.3)
Periodic Testing Requirements
23. On an annual basis, the owner or operator must complete site specific sampling including a
compositional analysis of the pre-flash pressurized condensate routed to these storage tanks
and, if necessary for emission factor development, a sales oil analysis to determine RVP and
API gravity. Testing must be in accordance with the guidance contained in PS Memo 05-01.
Results of testing must be used to determine site-specific emissions factors for VOC and
Hazardous Air Pollutants using Division approved methods.
Results of the Analysis must be used to demonstrate that the emissions factor established
through the Analysis are less than or equal to the emissions factor submitted with the permit
application and established herein in the "Notes to Permit Holder" for this emissions point. If
any site specific emissions factors developed through this Analysis are greater than the
emissions factors submitted with the permit application and established in the "Notes to Permit
Page 6 of 14
44r. COLORADO
., 0
/ Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Holder" the operator must submit to the Division within 60 days, or in a timeframe as agreed
to by the Division, a request for permit modification to address these inaccuracies.
24. On an annual basis, the owner or operator must conduct a source compliance test to measure
the mass emission rates of the pollutants listed below for each control device used,
demonstrate compliance with the emissions limits contained in this permit for each source, and
to demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC)
for each operating scenario. During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M;) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (MO using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(M;-Mo)/M,
The test protocol, test, and test report must be.in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with an annual emission limitation shall have the
results projected up to the annual averaging time by multiplying the test results by the
Process Limit(s) for that averaging time as indicated in the Process Limitations and Records
section of this permit.
Records of the annual compliance tests must be maintained by the owner or operator for a
minimum of five (5)years and made available to the Division for inspection upon request. If the
results of the periodic tests do not demonstrate compliance with the emissions limits contained
within this permit or do not demonstrate a minimum destruction efficiency of 98% for volatile
organic compounds (VOC), the owner or operator must submit to the Division within 60 days,
or in a timeframe as agreed to by the Division, a request for permit modification to address
these inaccuracies. (Regulation Number 3, Part B., Section III.G.3)
Page 7 of 14
ri. . COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ALTERNATIVE OPERATING SCENARIOS
25. The control devices may be replaced with a like-kind control devices in accordance with the
requirements of Regulation 3, Part A, Section IV.A and without applying for a revision to this
permit or obtaining a new construction permit. A like-kind control device shall be the same
make and model as authorized in this permit. All control device replacements installed and
operated as authorized by this permit must comply with all terms and conditions of this
construction permit. The owner or operator shall maintain a log on-site or at a local field
office to record the start and stop dates of any control device replacement, the
manufacturer, model number and serial number of the replacement control device.
26. An Air Pollutant Emissions Notice (APEN) that includes the specific manufacturer, model, and
serial number of the replacement control device must be filed with the Division within 14
calendar days of commencing operation of a replacement control device under the
Alternative Operating Scenario provision. The APEN must be accompanied by the appropriate
APEN filing fee and a cover letter explaining that the owner or operator is exercising an
Alternative Operating Scenario and has replaced the control device."
27. Within one hundred and eighty days (180) of startup of the replacement control device in
accordance with the Alternate Operating Scenario provision, the owner or operator must
conduct an initial source compliance test to measure the mass emission rates of the pollutants
listed below, demonstrate compliance with the emissions limit in this permit, and to
demonstrate a minimum destruction efficiency of 98% for volatile organic compounds (VOC).
During the test, the owner or operator must measure:
• mass emission rates of VOC at the inlet of the control device (M,) using EPA or other
division approved methods;
• mass emission rates of VOC at the outlet of the control device (M0) using EPA or other
division approved methods; and
• mass emission rates of NOx and CO at the outlet of the control device using EPA or
other division approved methods.
Additionally, the following parameters may be required to be measured during the test:
• combustion chamber temperature;
• gas flow rate;
• supplemental fuel flow rate;
• gas heat content; and
• gas composition.
The destruction efficiency (DE) for VOC must be calculated using the following equation:
DE (%) = 100*(M;-Mo)/Mi
The test protocol, test, and test report must be in accordance with the requirements of the
Air Pollution Control Division Compliance Test Manual. The test protocol must be submitted to
the Division for review and approval at least thirty (30) days prior to testing. No compliance
Page 8 of 14
r v, COLORADO
ill, wrio Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
test will be conducted without prior approval from the Division. Within thirty (30) days
following completion of the test(s), a compliance test report must be submitted to the
Division for review. Additional time may be granted upon written request. Any compliance
test conducted to demonstrate compliance with a monthly or annual emission limitation shall
have the results projected up to the monthly or annual averaging time by multiplying the test
results by the Process Limit(s) for that averaging time as indicated in the Process Limitations
and Records section of this permit. (Regulation Number 3, Part B., Section III.G.3)
Records of this AOS compliance tests must be maintained by the owner or operator for a
minimum of five (5) years and made available to the Division for inspection upon request. If the
results of the periodic tests do not demonstrate compliance with the emissions limits contained
within this permit or do not demonstrate a minimum destruction efficiency of 98% for volatile
organic compounds (VOC), the owner or operator must submit to the Division within 60 days,
or in a timeframe as agreed to by the Division, a request for permit modification to address
these inaccuracies. (Regulation Number 3, Part B., Section III.G.3)
ADDITIONAL REQUIREMENTS
28. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Existing New Emission Point
Permit Number Emission Point
GP01 123/9F3E/001 123/9F3E/001
29. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A,
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,t 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.
Page 9 of 14
r:,r.- COLORADO
Air Pollution Control Division
Department of Public Health a Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• 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.
30. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until
a permit is granted. (Regulation Number 3, Parts C and D).
GENERAL TERMS AND CONDITIONS
31. 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.
32. 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.
33. 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.
34. 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.
35. 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
Page 10 of 14
r:,�r COLORADO
410 t Air Pollution Control Division
Department of Public Health Er Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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.
36. 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.
37. 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:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to SRC Energy, Inc.
Page 11 of 14
�r,,�Y.... COLORADO
4. _
' j' Air Pollution Control Division
�� Department of Public Health&Environment
Dedicated to protecting and improving the hearth 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 5,806 116
Toluene 108883 6,320 126
Ethylbenzene 100414 201 4
001 Xylenes 1330207 2,340 47
n-Hexane 110543 52,362 1,047
2,2,4-
540841 295 6
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.
Page 12 of 14
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
5) The emission levels contained in this permit are based on the following emission factors:
Point 001:
Process 01: Condensate Throughput
Uncontrolled Controlled
CAS # Pollutant Emission Factors Emission Factors Source
lb/bbl lb/bbl
NOx 3.5E-03 3.5E-03 AP-42,
CO 1.6E-02 1.6E-02 Chapter 13.5
VOC 1.877 3.754E-02 ProMax
71432 Benzene 4.07E-03 8.14E-05 simulation of
108883 Toluene 4.43E-03 8.86E-05 flash, working,
100414 Ethylbenzene 1.41E-04 2.82E-06 and breathing
1330207 Xylene 1.64E-03 3.28E-05 emissions based
110543 , n-Hexane 3.67E-02 7.34E-04 on site-specific
_ pressurized
540841 2'2'4 2.07E-04 4.14E-06 liquid sample
Trimethylpentane taken 5/17/2017
Note: The controlled emissions factors for this point are based on a control efficiency of 98%.
Process 02: Combustion of Pilot Light Gas
Uncontrolled Controlled
Emission Emission
CAS # Pollutant Factors Factors Source
(lb/MMscf) (lb/MMscf)
NOx 82.688 82.688 AP-42,
CO 376.96 376.96 Chapter 13.5
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
1,216 Btu/scf. Pilot light fuel flow is based on a constant rate of 12.5 scf/hr per combustion device. This
point is controlled by 4 combustion devices.
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 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:
Page 13 of 14
C ,, ,,,e...: , COLORADO
Air Pollution Control Division
Department of Public Health&rnv ronment
Dedicated to protecting and improving the health and environment of the people of Colorado
Applicable Status
Requirement
Operating Permit Synthetic Minor Source of: VOC, CO, NOx, n-hexane, and total HAPs
PSD True Minor Source
NANSR Synthetic Minor Source of: VOC, NOx
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 M - Subpart DDD
MACT 63.1200-63.1439 Subpart EEE - Subpart PPP
MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY
MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM
MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX
Page 14 of 14
-r COLORADO
• J Air Pollution Control Division
Department of Public Health Fr Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
CONSTRUCTION PERMIT
Permit number: 19WE 1021 Issuance: 1
Date issued:
Issued to: SRC Energy, Inc.
Facility Name: SRC Wiedeman Pad
Plant AIRS ID: 123/9F3E
Physical Location: NWNE SEC 5 T5N R66W
County: Weld County
General
Description: Well Production Facility
Equipment or activity subject to this permit:
Equipment AIRS Equipment Description Emissions Control
ID Point Description
LDG-1 005 Truck loadout of condensate by Enclosed Combustion
submerged fill Device
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
more; (iii) does not complete construction within a reasonable time of the estimated
Page 1 of 10
C .,
M COLORADO
Air Pollution Control Division itV
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
completion date. The Division may grant extensions of the deadline. (Regulation Number 3,
Part B, Section III.F.4.)
F.4.)
3. 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
4. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3,
Part B, Section II.A.4)
Annual Limits:
Equipment ID AIRS Tons per Year Emission
Point PM2.5 NO, VOC CO Type
LDG-1 005 --- --- 1.0 --- Point
Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits.
Facility-wide emissions of each individual hazardous air pollutant must not exceed 8.0 tons per
year.
Facility-wide emissions of total hazardous air pollutants must not exceed 20.0 tons per year.
The facility-wide emissions limitation for hazardous air pollutants must apply to all permitted
emission units at this facility.
Compliance with the annual limits for both criteria and hazardous air 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.
5. The owner or operator must use the emission factors found in "Notes to Permit Holder" to
calculate emissions and show compliance with the limits. 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.
6. The owner or operator must track emissions from all insignificant activities at the facility on an
annual basis to demonstrate compliance with the facility emission limitations as indicated
below. An inventory of each insignificant activity and associated emission calculations must be
made available to the Division for inspection upon request. For the purposes of this condition,
insignificant activities are defined as any activity or equipment, which emits any amount but
does not require an Air Pollution Emission Notice (APEN) or is permit exempt. (Regulation 3,
Part C. II.E.)
.E.)
Page 2 of 10
-:,,. COLORADO
e CAir Pollution Control Division
i
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
Total potential emissions from the facility, including all permitted emissions and potential to
emit from all insignificant activities, must be less than:
• 50 tons per year of VOC.
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 Controlled
ID Point
LDG-1 005 Enclosed Combustion Device 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 rate 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/Consumption Limits
Equipment ID AIRS Process Parameter Annual Limit
Point
LDG-1 005 Condensate Loaded 175,200 barrels
The owner or operator must calculate 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. Visible emissions shall not exceed twenty percent (20%) opacity during normal operation of the
source. During periods of startup, process modification, or adjustment of control equipment
visible emissions shall not exceed 30%opacity for more than six minutes in any sixty consecutive
minutes. (Regulation Number 1, Section II.A.1. Et 4.)
10. This source is subject to the odor requirements of Regulation Number 2. (State only
enforceable)
11. Hydrocarbon liquids loadout from storage tanks to transport vehicles must be controlled by
using (a) submerge fill and (b) a vapor collection and return system and/or air pollution control
equipment. Compliance with Section II.C.5. must be achieved in accordance with the following
schedule: (Regulation Number 7, Part D, Section II.C.5.a.)
Page 3 of 10
r COLORADO
0 4.40 Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
• Facilities constructed or modified on or after May 1, 2020, must be in compliance by
commencement of operation.
• Facilities constructed before May 1, 2020, must be in compliance by May 1, 2021.
• Facilities not subject to Sections II.C.5.a.(i)(A) or II.C.5.a.(i)(B) that exceed the
hydrocarbon liquids loadout to transport vehicles throughput of greater than or equal to
5,000 barrels per year on a rolling 12-month basis must control emissions from loadout
upon exceeding the loadout threshold.
12. Storage tanks must operate without venting at all times during loadout. (Regulation Number 7,
Part D, Section II.C.5.a.(ii))
13. The owner or operator must, as applicable (Regulation Number 7, Part D, Section II.C.5.a.(iii)):
• Install and operate the vapor collection and return equipment to collect vapors during
the loadout of hydrocarbon liquids to tank compartments of outbound transport vehicles
and to route the vapors to the storage tank or air pollution control equipment.
• Include devices to prevent the release of vapor from vapor recovery hoses not in use.
• Use operating procedures to ensure that hydrocarbon liquids cannot be transferred to
transport vehicles unless the vapor collection and return system is in use.
• Operate all recovery and disposal equipment at a back-pressure less than the pressure
relief valve setting of transport vehicles.
• The owner or operator must inspect onsite loading equipment to ensure that hoses,
couplings, and valves are maintained to prevent dripping, leaking, or other liquid or
vapor loss during loadout. These inspections must occur at least monthly, unless loadout
occurs less frequently, then as often as loadout is occurring.
14. The owner or operator must perform the following observations and training (Regulation
Number 7, Part D, Section II.C.5.a.(iv)):
• The owner or operator must observe loadout to confirm that all storage tanks operate
without venting when loadout operations are active. These inspections must occur at
least monthly, unless loadout occurs less frequently, then as often as loadout is
occurring,
• If observation of loadout is not feasible, the owner or operator must document the
annual loadout frequency and the reason why observation is not feasible and inspect the
facility within 24 hours after loadout to confirm that all storage tank thief hatches (or
other access point to the tank) are closed and latched.
• The owner or operator must install signage at or near the loadout control system that
indicates which loadout control method(s) is used and the appropriate and necessary
operating procedures for that system.
• The owner or operator must develop and implement an annual training program for
employees and/or third parties conducting loadout activities subject to Section II.C.5.
Page 4 of 10
C ,, ,,.. ...:;.:
COLORADO
Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
that includes, at a minimum, operating procedures for each type of loadout control
system.
15. The owner or operator must retain the records required by Regulation Number 7, Part D, Section
II.C.5.a.(v) for at least two (2) years and make such records available to the Division upon
request.
• Records of the annual facility hydrocarbon liquids loadout to transport vehicles
throughput.
• Inspections, including a description of any problems found and their resolution, required
under Sections II.C.5.a.(iii) and II.C.5.a.(iv) must be documented in a log.
• Records of the infeasibility of observation of loadout.
• Records of the frequency of loadout.
• Records of the annual training program, including the date and names of persons
trained.
16. Air pollution control equipment used to comply with this Section II.C.5. must comply with
Section II.B., be inspected in accordance with Sections II.C.1.d.(ii) through (v), and achieve a
hydrocarbon control efficiency of 95%. (Regulation Number 7, Part D, Section II.C.5.a.(vi))
17. 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
18. Upon startup of these points, the owner or operator must follow the most recent operating
and maintenance (O&tM) plan and record keeping format approved by the Division, in order to
demonstrate compliance on an ongoing basis with the requirements of this permit. Revisions
to your O&M plan are subject to Division approval prior to implementation. (Regulation
Number 3, Part B, Section III.G.7.)
COMPLIANCE TESTING AND SAMPLING
Initial Testing Requirements
19. This source is not required to conduct initial testing, unless otherwise directed by the Division
or other state or federal requirement.
Periodic Testing Requirements
20. This source is not required to conduct periodic testing, unless otherwise directed by the Division
or other state or federal requirement.
Page 5 of 10
Cqp
.Mw�M COLORADO
�� Air Pollution Control Division
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
ADDITIONAL REQUIREMENTS
21. This permit replaces the following permits and/or points, which are cancelled upon issuance of
this permit.
Existing Permit Existing New Emission Point
Number Emission Point
GP07 123/9F3E/005 123/9F3E/005
22. 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 (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.
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.
23. Federal regulatory program requirements (i.e. PSD, NANSR) must apply to this source at any
such time that this source becomes major solely by virtue of a relaxation in any permit
condition. Any relaxation that increases the potential to emit above the applicable Federal
program threshold will require a full review of the source as though construction had not yet
commenced on the source. The source must not exceed the Federal program threshold until a
permit is granted. (Regulation Number 3, Parts C and D).
Page 6 of 10
C .:, COLORADO
4 Air Pollution Control Division
Department of Public Health 8 Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
GENERAL TERMS AND CONDITIONS
24. 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.
25. 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.
26. 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.
27. 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.
28. 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.
29. 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.
30. 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.
Page 7 of 10
COLORADO
-4.400 Y/ Air Pollution Control Division
t
Department of Public Health b Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
By:
Lauraleigh Lakocy
Permit Engineer
Permit History
Issuance Date Description
Issuance 1 This Issuance Issued to SRC Energy, Inc.
Page 8 of 10
Cr.y COLORADO
Air Pollution Control Division
Department of Public Health Fr Environment
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 72 4
005
n-Hexane 110543 631 32
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:
Uncontrolled Controlled
Pollutant CAS # Emission Emission Source
Factors Factors
lb/bbl lb/bbl
V0C 0.236 1.18E-02 CDPHE
Benzene 71432 0.00041 2.05E-05 State
Emission
n-Hexane 110543 0.0036 1.80E-04 Factors
Controlled emission factors are based on a flare efficiency of 95% and a collection efficiency of
100%.
Page 9 of 10
C ,. .,,,, ...» .
COLORADO
NPte Air Pollution Control Division
Department of Public Health&Environment
Dedicated to protecting and improving the health and environment of the people of Colorado
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, NOx, n-hexane, and total HAPs
PSD True Minor Source
NANSR Synthetic Minor Source of: VOC, NOx
8) 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.govl
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 XOOOO(
Page 10 of 10
CDPHE Hydrocarbon Liquid Loading APEN
4 ► Form APCD-208
CO Y•� Air Pollutant Emission Notice (APEN) and
II
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 fora new filing fee.
This APEN is to be used for hydrocarbon liquid loading only. 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,glycol dehydration unit,
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 at: www.cotorado.gov/cdphe/apcd.
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: / q (41E/01/ AIRS ID Number: 123 / 9F3E/ 005
[Leave blank unless APCD has already assigned a permit ri and AIRS ID]
Section 1 -Administrative Information
Company Name': SRC Energy, Inc.
Site Name: SRC Wiedeman Pad
Site Location
Site Location:
NWNE Sec. 5 T5N R66W County: Weld
NAICS or SIC Code: 211111
Mailing Address:
(include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634 Contact Person: Brad Rogers
Phone Number: (970)475-5242
E-Mail Address2: brogers@srcenergy.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.
421457
COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 1 Ithpanaa.
�
Permit Number: AIRS ID Number: 123 /9F3E/005
[Leave blank unless APCD has already assigned a permit"and AIRS ID]
Section 2 - Requested Action
0 NEW permit OR newly-reported emission source
0 Request coverage under construction permit O Request coverage under General Permit GP07
If General Permit coverage is requested,the General Permit registration fee of$312.50 must be
submitted along with the APEN filing fee.
-OR-
O MODIFICATION to existing permit(check each box below that applies)
❑ Change fuel or equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 0 Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
ADomoru 1 PERMIT AcnoNs-
❑ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE)
Additional Info&Notes: APEN Modification to convert current GP07 to an individual permit.
GP07 will be canceled upon issuance of the individual permit.
3 For company name change,a completed Company Name Change Certification Form(Form APCD-1O6)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: Contingency truck load out of condensate from storage tanks
Company equipment Identification No. (optional): LDG-1
For existing sources,operation began on: 03/22/2017
For new or reconstructed sources, the projected start-up date is:
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes ❑ No
Is this equipment located at a stationary source that is considered a Major Source of(HAP) ❑ Yes [J No
emissions?
Does this source load gasoline into transport vehicles? O Yes 0 No
Is this source located at an oil and gas exploration and production site? 0 Yes O No
If yes:
Does this source load less than 10,000 gallons of crude oil per day on an annual ❑ Yes 0 No
average?
Does this source splash fill less than 6750 bbl of condensate per year? O Yes 0 No
Does this source submerge fill less than 16308 bbl of condensate per year? ❑ Yes 0 No
Ay COLORADO
Form APCD-208 Hydrocarbon Liquid Loading APEN - Revision 3/2019 2 I
Permit Number: AIRS ID Number: 123 /9F3E/005
[Leave blank unless APCO has already assigned a permit C and AIRS ID]
Section 4- Process Equipment Information
Product Loaded: Q Condensate O Crude Oil O Other:
If this APEN is being filed for vapors displaced from cargo carrier, complete the following:
Requested Volume Loaded5: 175,200 bbl/year Actual Volume Loaded: 146,000 bbl/year
This product is loaded from tanks at this facility into: Tank Trucks
(e.g. "rail tank cars"or"tank trucks")
If site specific emission factor is used to calculate emissions,complete the following:
Saturation Factor: NIA Average temperature of NIA 'F
bulk liquid loading:
Molecular weight of
True Vapor Pressure: NIA Psia®60 `F NIA lb/lb mol
displaced vapors:
If this APEN is being filed for vapors displaced from pressurized loading lines, complete the
following:
Requested Volume Loaded5: N/A bbl/year Actual Volume Loaded: N/A bbl/year
Product Density: N/A lb/ft3
Load Line Volume: N/A ft3/truckload Vapor Recovery Line Volume: N/A ft3/truckload
5 Requested values will become permit limitations. Requested limit(s)should consider future process growth.
COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN - Revision 3/2019 3 I „,°„
Permit Number: AIRS ID Number: 123 19F3E 1005
[Leave blank unless APCD has already assigned a pernilt r and AIRS ID)
Section 5 - Stack Information
Geographical Coordinates
(LotitudelLongitude or UTM)
40.43311/-104.801741
Discharge Height Above 1
OperatorTemp. Flow Rate Velocity
Ground Level
Stack ID No. `F) (;AC (frlsec)
(leer} I
Leed L30-0011 25' 1,076 97.2 0.33
Indicate the direction of the stack outlet: (check one)
❑Upward O Downward O Upward with obstructing raincap
❑ Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
❑Circular Interior stack diameter(inches): 30
❑Other(describe):
Section 6 - Control Device Information
❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section.
O Loading occurs using a vapor balance system: Requested Control Efficiency:
Used for control of: VOCs and HAPs
Rating: 14.88 MMBtu/hr
Type: Enclosed Combustor Make/Model: Leed 30" L30-0011
Combustion
® Device: Requested Control Efficiency: 95 %
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1,076 °F Waste Gas Heat Content: 2,502.47 Btu/scf
Constant Pilot Light: ❑✓ Yes O No Pilot Burner Rating: 0.051 MMBtu/hr
Pollutants Controlled:
❑ Other: Description:
Requested Control Efficiency:
COLORADO
Form APCD-208 - Hydrocarbon Liquid Loading APEN - Revision 3/2019 4 t Y,rr ` ,
Permit Number: AIRS ID Number: 123 /9F3E/005
[Leave blank unless APCD has already assigned a permit x and AIRS ID]
Section 7- 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(%reduction):
Overall Requested
Pollutant Description of Control Method(s) Control Efficiency
(%reduction in emissions)
PM
SOx
NOx
CO ,
VOC Enclosed Combustor 95%
HAPs Enclosed Combustor 95%
Other:
El Using State Emission Factors(Required for GP07) VOC Benzene n-Hexane
0 Condensate 0.236 Lbs/BBL 0.00041 Lbs/BBL 0.0036 Lbs/BBL
❑Crude 0.104 Lbs/BBL n 0.00018 Lbs/BBL 0.0016 Lbs/BBL
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Requested Annual Permit
Emission Factor Actual Annual Emissions Emission Limit(s)s
Pollutant
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (AP-42, Emissions Emissions6 Emissions Emissions MI,.,etc.) (tons/year) (tons/year) (tons/year) (tarstyear)
PM N/A N/A N/A N/A N/A N/A N/A
SOx N/A N/A N/A N/A N/A N/A N/A
NOx N/A N/A N/A N/A N/A N/A N/A
CO N/A N/A N/A N/A N/A N/A N/A
VOC 0.236 Ibs/bbl CDPHE 17.23 0.86 20.67 1.03
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions
Number Basis Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 0.00041 lbs/bbl CDPHE 60.74 3.04
Toluene 108883 N/A N/A N/A N/A N/A
Ethylbenzene 100414 N/A N/A N/A N/A N/A
Xylene 1330207 N/A N/A N/A N/A N/A
n-Hexane 110543 0.0036 Ibs/bbl CDPHE 527.06 26.35
2'2'4 540841 N/A N/A N/A N/A WA
Trimethylpentane
Other:
5 Requested values will become permit limitations.Requested limit(s)should consider future process growth.
6 Annual emissions fees will be based on actual controlled emissions reported. If source has not yet started operating,leave
blank.
COLS♦0
Form APCD-208- Hydrocarbon Liquid Loading APEN Revision 3/2019 5 1 ,� O^°::."°"°
0
11q.nk nro ,
Permit Number: AIRS ID Number: 123 /9F3E/005
[Leave btanl- untess APCD has already assigned a permit 4 and AIRS ID[
Section 8 -Applicant Certification
I hereby certify that alt information contained herein and information submitted with this application is complete,
true, and correct. If this is a registration for coverage under General Permit GP07, I further certify that this source
is and will be operated in full compliance with each condition of General Permit GP07.
Pi Zjii
Signature of Legally Authorized Person(not a vendor or consultant) Date
Brad Rogers Health and Environmental Manager
Name(print) Title
Check the appropriate box to request a copy of the:
Q Draft permit prior to issuance
❑� 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 5191.13 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.colorado.gov/cdphe/apcd
Aw COLORADO
Form APCD-208- Hydrocarbon Liquid Loading APEN Revision 3/2019 6 I AZIN " .
APEN Superseded - See Attached Addendum
Received 08/05/2020
CDPHE Condensate Storage Tank(s) APEN
Form APCD-205
CO
� Air Pollutant Emission Notice (APEN) and
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 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.Rov/pacific/cdphefair-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: L1 WE/QZ AIRS ID Number: 123 /9F3E/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 -Administrative Information
Company Name1: SRC Energy, Inc.
Site Name: SRC Wiedeman Pad
Site Location
Site Location:
NWNE Sec. 5 T5N R66W County: Weld
NAICS or SIC Code: 211111
Mailing Address:
(include Zip Code) 5400 W. 11th Street, Suite C
Greeley, CO 80634 Contact Person: Brad Rogers
Phone Number: (970)475-5242
E-Mail Address2: brogers@srcenergy.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.
421456
COLORADO
Form APCD-205 - Condensate Storage Tank(s)APEN - Revision 3/2019 1 I •
Permit Number: AIRS ID Number: 123 I 9F3E/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID
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
0 GP01 0 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-
0 MODIFICATION to existing permit(check each box below that applies)
❑ Change in equipment 0 Change company name3
❑ Change permit limit O Transfer of ownership' ❑Q Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDn1ONAL PERMIT ACTIONS-
▪ 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: APEN Modification to update throughput and convert current GP01 to an individual permit.
Emission factors are from the GP01 application.The GP01 will be canceled upon issuance of the individual permit.
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: Storage of condensate from production wells
Company equipment Identification No. (optional): TNK 1-10
For existing sources, operation began on: 03/22/2017
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&Production(E&P)site 0 Midstream or Downstream(non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? 0 Yes 0 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: 0.004 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission(COGCC) 0 Yes ❑ No
805 series rules?If so, submit Form APCD-105.
Are you requesting z 6 ton/yr VOC emissions(per storage tank),or are uncontrolled actual 0 Yes ❑ No
emissions z 6 ton/yr(per storage tank)?
Ay COIOItA !DO
Form APCD-205 Condensate Storage Tank(s)APEN - Revision 3/2019 2 "^�
MNhM6EP.xWA
•
Permit Number: AIRS ID Number: 123 I 9F3E I 001
)leave blank unless APCD has already assigned a permit r and AIRS ID]
Section 4- Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbl/year) (bbllyear)
Condensate Throughput: 1,460,000 1,752,000
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 48.6 degrees RVP of sates oil: 7.7
Tank design: El Fixed roof ❑Internal floating roof ❑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)
TNK 1-10 10 4,000 02/2017 03/2017
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Oniy)
API Number Name of Well Newly Reported Well
05 •123 40063 SRC Wiedeman#22-5-4NBHZ ❑
05 -123 -40064 SRC Wiedeman#A-5-3NBHZ O
05 123 •40065 SRC Wiedeman#12-5-4CHZ ❑
05 -123 •40066 SRC Wiedeman#11-5-3NCHZ ❑
05 -123 -40067 SRC Wiedeman#22-5-4CHZ O
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 welts that are serviced by the equipment reported on this APEN form.
Section 5 - Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.43311/-104.801741
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(feet) (°F) (ACFM) (ft/sec)
(4) IES 27.25' 1,076 451.4 0.19
Indicate the direction of the stack outlet: (check one)
0 Upward 0 Downward 0 Upward with obstructing raincap
❑Horizontal ❑Other(describe):
Indicate the stack opening and size: (check one)
0 Circular Interior stack diameter(inches): 85.5
❑Square/rectangle Interior stack width(inches): Interior stack depth(inches):
❑Other(describe):
COLORADO
Form APCD-205- Condensate Storage Tank(s) APEN - Revision 3/2019 3 i [) ,
Permit Number: AIRS ID Number: 123 /9F3E/001
[Leave blank unless APCD has already assigned a perle t e and AIRS ID]
Section 6 - Control Device Information
❑ 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):
Pollutants Controlled: VOCs and HAPs
Rating: 269.62 MMBtu/hr
Type: (4)Enclosed Cornbustors Make/Model: (4) IES S - 96"
Q Combustion Requested Control Efficiency: 98
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1,076°F Waste Gas Heat Content: 2,490 Btu/scf
Constant Pilot Light: ❑ Yes 0 No Pilot Burner Rating: 0.061 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
O Other: Description:
Control Efficiency Requested:
II
Section 7- Gas/Liquids Separation Technology Information (E&P Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 19 psig
Describe the separation process between the well and the storage tanks:
(24) Horizontal 48"Leed separators, (4)Vertical knockout separators, (1)Worthington 60"gasbuster
ORADO
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 3/2019 4 , V COCO
x..44. . ,
Permit Number: AIRS ID Number: 123 /9F3E/001
[Leave blank unless APCD has atreadv assigned a permit 4'and 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(%reduction):
Overall Requested Control
Pollutant Description of Control Method(s) Efficiency
(%reduction in emissions)
VOC Enclosed Combustors 98%
NOx
CO
HAPs Enclosed Combustion 98%
Other:
From what year is the following reported actual annual emissions data? 2019
Criteria Pollutant Emissions Inventory
Emission Factor? Actual Annual Emissions Requested Annual Permit
Red-lines per Emission fimit(s)s
attached email Pollutant
Source Uncontrolled Controlled Uncontrolled Controlled
approval recd Uncontrolled Bash Units (AP-42, Emissions Emissions= Emissions Emissions
6/26/20. Mfg.,etc.) (tau/yam) (tons/year) (tau/Year) (tons/year)
s/year)
-LL VOC 1.877 Ibs/bbi ProMax 1,370.57 27.41 1,644.69 32.8932.9C
NOx 0.068 Ib/MMBtu AP-42 N/A 249_2.57 N/A 3.35 3.08
CO 0.31 lb/MMBtu AP-42 N/A 12.7411.7, NIA 15.27 14.0e
Non-Criteria Reportable Pollutant Emissions Inventory
Chemical Emission Factor? Actual Annual Emissions
Chemical Name Abstract Source Uncontrolled Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions
Number Mfg.,etc.) (pounds/year) (pounds/year)
Benzene 71432 4.07E-03 Ibs/bbl ProMax 5,942.20 118.84
Toluene 108883 4.43E-03 Ibs/bbi ProMax 6,467.80 129.36
Ethylbenzene 100414 1.41E-04 Ibs/bbi ProMax 205.86 4.12
Xylene 1330207 1.64E-03 Ibs/bbl ProMax 2,394.40 47.89
n-Hexane 110543 3.67E-02 Ibs/bbI ProMax 53,586.61 1,071.73
2,2'4 540841 2.07E-04 lbs/bbl ProMax 302.22 6.04
Trimethylpentane
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.
8 Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave
blank.
ACOLD#ADO
V Form APCD-205- Condensate Storage Tank(s)APEN - Revision 3/2019 5 1 °""411.:11°"
Permit Number: AIRS ID Number: 123 i9F3E/001
[Leave blank unless APCD has already assigned a permit n 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.
Z3 l 2011
Signature of Legally Authorized Person(not a vendor or consultant) Date
Brad Rogers Health and Environmental Manager
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 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.colorado.govicdphe/apcd
COLORADO
Form APCD-205 Condensate Storage Tank(s)APEN - Revision 3/2019 6 i diklY „�;' „,
E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form'
Company Name: SRC Energy,Inc.
Source Name: Condensate Tanks-SRC Wiedeman Pad
Emissions Source AIRS ID2: 123/9F3E/001
Wells Services by this Storage Tank or Tank Battery (E&P Sites Only)
API Number Name of Well Newly Reported Well
05-123-40068 SRC Wiedeman#12-5-4NCHZ 0
05-123-40069 SRC Wiedeman#21-5-3NBHZ ❑
05-123-40560 SRC Wiedeman#21-5-3CHZ ❑
05-123-45397 Boomerang 33C-6-M ❑
05-123-45396 Boomerang 32N-6B-M ❑
05-123-45389 Boomerang 34N-6A-M ❑
05-123-45393 Boomerang 33N-6C-M 0
05-123-45392 Boomerang 32N-6C-M ❑
05-123-45395 Boomerang 32C-6-M ❑
05-123-460O0 Boomerang 25N-3A-L ❑
05-123-45398 Boomerang 13C-6-M ❑
05-123-45399 Boomerang 12N-6B-M ❑
05-123-45999 Boomerang 25N-3B-L ❑
05-123-45394 Boomreang 12C-6-M ❑
05-123-45391 Boomerang 13N-6B-M ❑
05-123-45998 Boomerang 28N-3A-L ❑
05-123-45997 Boomerang 28C-3-L ❑
05-123-45400 Boomerang 34C-6-M ❑
05-123-45390 Boomerang 34N-6C-M ❑
- - ❑
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 CondTank-APEN-Addendum.docx
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
STATE OF
COLORADO Lakocy-CDPHE, Lauraleigh<Iauraleigh.Iakocy@state.co.us>
FW: [EXTERNAL] :Fwd: SRC Energy - SRC Wiedeman Pad - Permitting Requests
Jack Starr<Jack.Starr@pdce.com> Fri, Jun 26, 2020 at 4:05 PM
To: "Lakocy-CDPHE, Lauraleigh" <lauraleigh.lakocy@state.co.us>
Hi Lauraleigh,
Thanks for allowing me a little more time with these. I really appreciate it! Please proceed with the redlines to the
condensate tanks APEN to match the calculations provided. After the redlines have been made, can I get a copy of the
APEN?
I have attached an updated O&M plan for the condensate tanks and loadout as well as an updated 102 Form.As far
as I know,the two Cummins engines (points-002 and -006, respectively)are no longer on site. Upon confirmation of
that, I will submit cancellation requests for each engine.As for the Doosan 21.9L, I believe it was included in that
1/24/2019 package that contained the other GP02s. I have attached a copy of the APEN for reference.
Finally, please see below for PDC's comments on draft permits 19WE1020 and 19WE1021.
Permit 19WE1020
Permit Condition 1: Requirement to Submit a Notice of Startup—As this is an existing source that was previously
permitted under a GP01, can this condition be removed? If not, can I submit an electronic NOS and send you a copy
of it to get this condition removed?
Permit 19WE1021
Permit Condition 1: Requirement to Submit a Notice of Startup—As this is an existing source that was previously
permitted under a GP07, can this condition be removed? If not, can I submit an electronic NOS and send you a copy
of it to get this condition removed?
If you need anything else from me, or would like to discuss any of this, please do not hesitate to let me know.
Have a great weekend!
Jack Starr
Senior Air Quality Representative-Wattenberg
https://mail.google.com/mail/u/0?ik=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1670600868267704925&simpl=msg-f%3A1670600868... 1/20
7/14/2020 State.co.us Exedutive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
(303)318-61611 Direct
(720)501-8611ICell
Cell
Jack.Starr@pdce.com
•
IA% PDC
ENERGY
PDC Energy 1 1775 Sherman Street Ste 3000 I Denver, CO 80203 I NASDAQ:PDCE
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pia Please consider the environment before printing this e-mail. Thank You.
From: Lakocy-CDPHE, Lauraleigh [mailto:lauraleigh.lakocy@state.co.us]
Sent: Monday,June 22, 2020 12:07 PM
To:Jack Starr<Jack.Starr@pdce.com>
Subject: Re: FW: [EXTERNAL] :Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
Hi Jack,
That works for me!
Please note that at this time, I do believe these permits will need to go to public comment as they will be seeking new
synthetic minor limits under 50 tpy for the entire facility in the nonattainment area. Additionally, I do anticipate going on
some extended leave likely starting in late August, but want to get those permits requiring public comment sent to public
comment within the next few weeks so that once their notice period has concluded, I can get those finalized before I am
out!
Let me know if you have any questions and I will look forward to your comments/feedback!
Sincerely,
Lauraleigh Lakocy
Oil £t Gas Permit Engineer
Oil and Gas Program
https://mail.google.com/mai I/u/0?i k=44f88835c3&view=pt&search=al I&permmsg id=msg-f%3A1670600868267704925&simpl=msg-f%3A1670600868... 2/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
P 303.692.3146***
4300 Cherry Creek Drive South, Denver, CO 80246
Lauraleigh.Lakocy@state.co.us I www.colorado.gov/cdphe/apcd
Questions on Air Pollution Control Division operations during COVID-19 response?Visit our FAQ Page.
***At this time, I am working remotely. While I will have regular access to my voicemail, the best way to reach me
will be through email.
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
On Mon, Jun 22, 2020 at 10:27 AM Jack Starr<Jack.Starr@pdce.com>wrote:
Good Morning Lauraleigh,
I apologize, but I haven't had a chance to review these draft permits yet. Can I please have until the end of this
week(6/26)to get you PDC's comments?
Jack Starr
Senior Air Quality Representative-Wattenberg
(303)318-61611 Direct
(720)501-8611 I Cel I
Jack.Starr@pdce.com
IA PDC
ikeir ENERGY
PDC Energy 1 1775 Sherman Street Ste 3000 I Denver, CO 80203 I NASDAQ: PDCE
https://mai I.google.cam/mai I/u/0?i k=44f88835c3&view=pt&search=all&permmsgid=msg-f%3A1670600868267704925&simpl=msg-f%3A1670600868... 3/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
This email,including attachments,may include confidential and/or proprietary information,and may be used only by the person or entity to which it is
addressed. Please do not read,copy or disseminate this communication unless you are the intended addressee.If you received this communication in error,
please permanently delete and call(800)624-3821 immediately and ask to speak to the sender of this communication. Also,please notify immediately via e-
mail that you have received this message in error.
`"A Please consider the environment before printing this e-mail. Thank You.
From: Lakocy-CDPHE, Lauraleigh [mailto:lauraleigh.lakocy@state.co.us]
Sent:Thursday,June 4, 2020 12:39 PM
To:Jack Starr<Jack.Starr@pdce.com>
Subject: Re: FW: [EXTERNAL] :Fwd: SRC Energy-SRC Wiedeman Pad- Permitting Requests
Good Afternoon Jack,
Thank you so much for this information. With that, may I make the following red-line changes to the condensate tanks
APEN to match the calculations provided?
Actual Controlled Requested Controlled
NQx CO VOC Nr?x CO VOC
Combustor P t Light Emassxxts 0.02 0,08 0.00 0.02 0 08 0.00
Tori Ertusstons 2.56 11.65 271 t 3.07 13.98 32 49
Total Emissions 2.57 .11.73 17-41 3.®S 14.06 32-90
Because the loadout emissions are non-reportable for the combustion emissions,there is not a need to make any
changes to that APEN.
I have attached draft permits for you to review. Please note that these are being issued to SRC Energy, Inc as that is
who the application came in from. While I understand that the Transfer of Ownership is in process, upon speaking with
Paul Rusher, he recommended this path forward. Can you provide any feedback on these draft permits by Thursday,
June 18, prior to these permits going to public notice?
Can you please provide updated O&M plans for the loadout and condensate tanks? Since this application was
submitted,we have published updated O&M plans to reflect the requirements due to the ozone nonattainment
redesignation.
Also, can you provide an updated Form APCD-102? I do see that there was a GP02 requested and processed for a
PSI 8.1L engine; however, according to the facility inventory form submitted, it looks like there are 3 other engines that
should be permitted. I am aware of 2-GP02 permits that were received 1/24/2019 and have not yet been processed
(Doosan 11.1L&Caterpillar G3406TA)- I am following up on their status as I know there were some administrative
errors,.but I think we may still be missing an engine (Doosan 21.9L). Do you have records as to when an APEN was
submitted for that point?We do have an AIRS Point 002 that has a GP02 for a Cummins 225 HP engine and a GP06
under point 004 for a Cummins 363 diesel engine, which do not appear to have been cancelled.Are those still
active/on-site?
Let me know if you have any questions &thank you so much for your assistance with moving these permits forward!
Sincerely,
https://m ai I.google.com/mai I/u/0?i k=44f88835c3&view=pt&search=al I&permmsg id=msg-f%3A 1670600868267704925&simpl=msg-f%3A 1670600868... 4/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
Lauraleigh Lakocy
Oil £t Gas Permit Engineer
Oil and Gas Program
P 303.692.3146***
4300 Cherry Creek Drive South, Denver, CO 80246
Lauraleigh.Lakocy@state.co.us I www.colorado.gov/cdphe/apcd
Questions on Air Pollution Control Division operations during COVID-19 response?Visit our FAQ Page.
***At this time,I am working remotely. While I will have regular access to my voicemail, the best way to reach
me will be through email.
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
On Thu, May 28, 2020 at 2:14 PM Jack Starr<Jack.Starr@pdce.com>wrote:
Hi Lauraleigh,
Again, I apologize for the delay here. Please see below for answers to your questions in blue. Please let me know
if you have additional questions or need anything else from me as you continue your review.
• For the condensate storage tanks and the condensate loadout,this source has requested
98%control. Would you like to proceed with this application requesting 98%control?As I had
mentioned to Brad/Chad,this will lead to increased sampling, monitoring, and testing requirements.
Please proceed with 98% control on the condensate storage tanks. As far as the condensate loadout
control goes, it looks to me like 95%was requested on the APEN, but I might be missing something.
Either way, PDC would prefer to only claim 95%control for condensate loadout as it is controlled by
a separate combustor.
o If you would like to request 98%control for these sources, can you please provide
make/model/serial numbers for all combustors used to control these 2 sources?All four
combustors are IES (make) 96" (model). The serial numbers are:01-07, 01-08,01-35, and 01-36.
• In the original applications, it appears that the volume of vapors combusted for the
condensate storage tanks had considered an additional 20% buffer in terms of calculating
combustion emissions,according to my emailing with Chad Powell.This is not a standard practice
for construction permits,as the source requests their PTE for condensate throughput and the
https://mai I.google.com/mail/u/0?i k=44f88835c3&view=pt&sea rch=all&permmsg id=msg-f%3A1 6 706 00868 2 67704 92 5&simpl=msg-f%3A1670600868... 5/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
emissions should be based on that value. Would you like to maintain the original request or modify
the combustion emissions?This one took some time for me to wrap my head around. I came to the
same conclusion as you seemed to initially, in that the ProMax run included yields a throughput of
about 1,585,785 bbls/yr. After reviewing previous submittals for this facility, it would appear the
included ProMax run was for the GP01 update made in January of 2019 for this site. I'm assuming
SRC/LT included it with this package purely as reference to use the previously approved emission
factors. Using that ProMax run, I calculate a GOR of 20.686 scf/bbl. Using that same GOR with the
actual and requested throughputs from this submittal, I calculate the emissions shown below(pilot
emissions included).These seem to match the values you originally suggested to Chad/Brad, but I
would just like to confirm that's the case and that we arrived at those values in a similar manner.
o Actuals:2.57 TPY NOx& 11.73 TPY CO
o Requested:3.08 TPY NOx& 14.06 TPY CO
• The original combustion emissions did not consider the VOC emissions from the pilot light
combustion.We have begun including these calculations within our analysis and also our permitted
limits for sources controlled by combustion devices. Can you please submit VOC combustion
emission calculations?We typically see sources use the emissions factors from AP-42,Chapter 1,
Table 1.4-2. Please see the attached pilot light calc sheet.The fuel usage and heat content used
were those from last October's submittal. These values, in conjunction with the EFs from Table 1.4-
2,yield a small enough value that when rounded to the hundredth (as is done in the calc sheet)they
appear to be zero. When the decimal is carried out a little further, however,the value is 1.34 x 10^-3
TPY VOC for the tank combustors and 3.36 x 10^-4 TPY VOC for the loadout combustor.
Jack Starr
Senior Air Quality Representative-Wattenberg
(303)318-61611 Direct
(720)501-8611 I Cel I
Jack.Starr@pdce.com
trA PDC
NAY ENERGY
PDC Energy 1 1775 Sherman Street Ste 3000 I Denver, CO 80203 1 NASDAQ:PDCE
This email,including attachments,may include confidential and/or proprietary information,and may be used only by the person or entity to which it is
addressed. Please do not read,copy or disseminate this communication unless you are the intended addressee.If you received this communication in
error,please permanently delete and call(800)624-3821 immediately and ask to speak to the sender of this communication. Also,please notify
immediately via e-mail that you have received this message in error.
`"' Please consider the environment before printing this e-mail. Thank You.
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7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
From: Lakocy-CDPHE, Lauraleigh [mailto:lauraleigh.lakocy@state.co.us]
Sent:Tuesday, May 26, 2020 2:34 PM
To:Jack Starr<Jack.Starr@pdce.com>
Subject: Re: FW: [EXTERNAL] :Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
Hi Jack,
I just re-sent you invitations to view the documents- I wish it would just let me attach them to the email, as that
would be my preference. If this does not work, the original application materials can be found on our records
management system (https://environmentalrecords.colorado.gov/HPRMWebDrawer/Search), records 123-9F3E-18,
123-9F3E-19, 123-9F3E-20.
Let me know if you have any additional questions.
Sincerely,
Lauraleigh Lakocy
Oil Ft Gas Permit Engineer
Oil and Gas Program
P 303.692.3146
4300 Cherry Creek Drive South, Denver, CO 80246
Lauraleigh.Lakocy@state,co.us I www.colorado.gov/cdphe/apcd
Questions on Air Pollution Control Division operations during COVID-19 response?Visit our FAQ Page.
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
On Thu, May 21, 2020 at 3:01 PM Jack Starr<Jack.Starr@pdce.com>wrote:
Hi Lauraleigh,
I apologize, but I'm just getting to this. When I try to view the links to the PDFs, it takes me to Google Drive
but then shows the file(s) can't be previewed. Is there a chance I waited too long and the link expired? If so,
https://mai I.google.com/mai I/u/0?i k=44f88835c3&view=pt&search=al I&perm msg id=msg-f%3A 1670600868267704925&simpl=msg-f%3A 1670600868... 7/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests •
can I please get you to re-send the links or copies of the PDFs?
Thanks,
Jack Starr
Senior Air Quality Representative-Wattenberg
(303)318-6161 I Direct
(720)501-8611 I Cell
Jack.Starr@pdce.com
(e)
PDC Energy 11775 Sherman Street Ste 3000 I Denver, CO 80203 I NASDAQ:PDCE
This email,including attachments,may include confidential and/or proprietary information,and may be used only by the person or entity to which it is
addressed. Please do not read,copy or disseminate this communication unless you are the intended addressee.If you received this communication in
error,please permanently delete and call(800)624-3821 immediately and ask to speak to the sender of this communication. Also,please notify
immediately via e-mail that you have received this message in error.
Please consider the environment before printing this e-mail. Thank You.
From: Lakocy-CDPHE, Lauraleigh [mailto:lauraleigh.lakocy@state.co.us]
Sent: Monday, May 18, 2O20 4:55 PM
To:Jack Starr<Jack.Starr@pdce.com>
Subject: Re: FW: [EXTERNAL] :Fwd:SRC Energy-SRC Wiedeman Pad- Permitting Requests
Hi Jack,
Absolutely-just keep me updated in case you need additional time!
Sincerely,
Lauraleigh Lakocy
Oil Ft Gas Permit Engineer
Oil and Gas Program
https://mai I.google.com/mai I/u/0?ik=44f88835c3&view=pt&search=al I&permmsg id=msg-f%3A1670600868267704925&simpl=msg-f%3A1670600868... 8/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
I I
P 303.692.3146
4300 Cherry Creek Drive South, Denver, CO 80246
Lauraleigh.Lakocy@state.co.us I www.colorado.gov/cdphe/apcd
Questions on Air Pollution Control Division operations during COVID-19 response?Visit our FAQ Page.
Are you curious about ground-level ozone in Colorado?Visit our ozone webpage to learn more.
On Fri, May 15, 2020 at 5:05 PM Jack Starr<Jack.Starr@pdce.com>wrote:
Hi Lauraleigh,
I apologize for the delay on this. I haven't had a chance to give this much of a review yet, but am planning
on digging into it early next week. Can I get back to you mid-week next week?
Have a great weekend!
Jack Starr
Senior Air Quality Representative-Wattenberg
(303)318-61611 Direct
(720)501-86111 Cell
Jack.Starr@pdce.com
I 11 PDC
7 ENERGY
PDC Energy 11775 Sherman Street Ste 3000 I Denver, CO 80203 I NASDAQ: PDCE
https://mai I.google.com/mai I/u/0?i k=44f88835c3&view=pt&search=al I&permmsg id=msg-f%3A 1670600868267704925&simpl=msg-f%3A 1670600868... 9/20
7/14/2020 State.co.us Executive Branch Mail-FW:[EXTERNAL]:Fwd:SRC Energy-SRC Wiedeman Pad-Permitting Requests
This email,including attachments,may include confidential and/or proprietary information,and may be used only by the person or entity to which
it is addressed. Please do not read,copy or disseminate this communication unless you are the intended addressee.If you received this
communication in error,please permanently delete and call(800)624-3821 immediately and ask to speak to the sender of this communication.
Also,please notify immediately via e-mail that you have received this message in error.
Please consider the environment before printing this e-mail. Thank You.
From: Lakocy-CDPHE, Lauraleigh [mailto:lauraleigh.lakocy@state.co.us]
Sent:Tuesday, May 12, 2020 9:50 AM
To:Jack Starr<Jack.Starr@pdce.com>
Subject: Re: FW: [EXTERNAL] :Fwd:SRC Energy-SRC Wiedeman Pad -Permitting Requests
Dear Jack,
I had been working on the permitting requests for the SRC Wiedman Pad. I had some outstanding questions
that had not yet been addressed upon the transfer of ownership, in addition to some concerns regarding
calculations not matching.Would you be able to review the requests below and let me know how you like to
move forward? I have attached the original APENs and permit application for your reference.
• For the condensate storage tanks and the condensate loadout, this source has requested 98% control.
Would you like to proceed with this application requesting 98% control?As I had mentioned to
Brad/Chad, this will lead to increased sampling, monitoring, and testing requirements.
a If you would like to request 98% control for these sources, can you please provide
make/model/serial numbers for all combustors used to control these 2 sources?
• In the original applications, it appears that the volume of vapors combusted for the condensate storage
tanks had considered an additional 20% buffer in terms of calculating combustion emissions, according
to my emailing with Chad Powell. This is not a standard practice for construction permits, as the source
requests their PTE for condensate throughput and the emissions should be based on that value. Would
you like to maintain the original request or modify the combustion emissions?
• The original combustion emissions did not consider the VOC emissions from the pilot light combustion.
We have begun including these calculations within our analysis and also our permitted limits for sources
controlled by combustion devices. Can you please submit VOC combustion emission calculations?We
typically see sources use the emissions factors from AP-42, Chapter 1, Table 1.4-2.
I think these questions should get these permits moving again. I realize that this will be a new request for you
that you likely have not reviewed, so please let me know if you have any questions. I am currently working
remotely, so if you would like to set-up a phone conference, let me know and I would be happy to schedule
that.
Thank you!
Sincerely,
Lauraleigh Lakocy
Oil & Gas Permit Engineer
Oil and Gas Program
https://mai I.google.com/mail/u/0?i k=44f88835c3&view=pt&search=al I&permmsgid=msg-f%3A1670600868267704925&simpl=msg-f%3A167060086... 10/20
Received 5/28/2020
Company Name:PDC Energy,Inc.
Facility Name:Wiedeman/Boomerang Pad
Condensate Tank Pilot Light Emissions Calculations
Actual Fuel Requested Fuel Annual Fuel Fuel Htg Emission Factors Actual Pilot Emissions Requested Pilot Emissions
Reference Consumption Consumption Op Time Type Value NOx' CO' VOC 2 NOx CO VOC NOx CO VOC
ID scf/hr scf/hr (hours) (Btu/scf) (lb/MMBtu) (lb/MMBtu) (Ib/MMscf) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY)
Tank Combustor 1 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Tank Combustor 2 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Tank Combustor 3 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00_ 0.00 0.00 0.00 0.02 0.00 0.00
Tank Combustor 4 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Total Emissions: 0.00 0.02 0.02 0.08 0.00 0.00 0.00 0.02 0.02 0.08 0.00 0.00
_ Actual Controlled Requested Controlled
NOx CO VOC NOx CO VOC
Combustor Pilot Light Emissions 0.02 0.08 0.00 0.02 0.08 0.00
Tank Emissions 2.56 11.65 27.41 3.07 13.98 32.89
Total Emissions 2.57 11.73 27.41 3.08 14.06 32.90
Condensate Truck Loadout Combustor Pilot Light Emissions Calculations
Actual Fuel Requested Fuel Annual Fuel Fuel Htg Emission Factors Actual Pilot Emissions Requested Pilot Emissions
Reference Consumption Consumption Op Time Type Value NOx' CO' VOC 2 NOx CO VOC NOx CO VOC
ID scf/hr scf/hr (hours) (Btu/scf) (lb/MMBtu) (lb/MMBtu) (Ib/MMscf) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY)
Loadout Combustor 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Total Emissions: 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Actual Controlled Requested Controlled
NOx CO VOC NOx CO VOC
Loadout Combustor Pilot Light Emissions 0.00 0.02 0.00 0.00 0.02 0.00
Loadout Emissions 0.02 0.08 0.86 0.02 0.10 1.03
Total Emissions 0.02 0.10 0.86 0.03 0.12 1.03
1-NOx and CO emission factors from AP-42 Table 13.5-1 Emission Factors for Flare Operations
2-VOC emission factor from AP-42 Table 1.4-2 Emission Factors for Criteria Pollutants and Greenhouse Gases From Natural Gas Combustion
Example Calculations:
Emissions(lb/hr)=EF(lb/MMBtu)•Fuel Consumption(scf/hr)•Fuel Htg Value(Btulscf)•1 MMBtullx10 'Btu
Emissions(lb/hr)=EF(Ib/MMscf)•Fuel Consumption(scf/hr)•1 MMscf/1x10 `scf
Emissions(TPY)=Emissions(Ib/hr)*Annual Operating Time(hr/yr)•1 ton/2000 lb
Received 6/26/2020
Colorado Department of Public Health and Environment
Form APCD-102 Air Pollution Control Division
CDPHE
Facility Wide Emissions Inventory Form 13
v .April,2015
Company Name:PDC Energy,me
Source Name:Wledeman/13oomcmng Pad
Source AIRS ID:123/9F3E
Iloeonttolkd Potenti%to Emit(POE) Controlled Pureed.to Emit OTE)
criteria row) I IIAPsaloryr) C11010In(TPY) HAP.01640
Al104xa Equipment Description TIP PM10 P542.5 1112 WOO VOI CO I ArealmuCO ArnAu P1 Mil EH Nyl o-Hex Meth 224-TMP TIP P1110 PM1.5 502 NO, VOC CO RCHO Oretel Acre HL Tol RS Cy1 o-Hex Meth 224-TMP
1231963E01(1 ('801001,T.JII 0.00 .101 0.00 0.00 0.90 1644.69 0.(1(1 1 0.1X( 7,130.64 2161.36 247.03 2.873.28 64.30193 0.00 362.66 10111 090 0.00 um .3.08 3393 14.(16 142.61 15523 a 4.94 57.47 138602 0110 7.25
123:99311005 Cundvualc Load0ul 0.09 211.67 1000 0.011 0.00 0.00 72.88 0,011 OM 0,00 632.47 0.0 1.113 0.12 464 31.62 0.110 0.00
1239636,00.3 24ukuJ Wider Tanks 12.01 0 I 2181.34 357.22 13.26 14(1.56 370.41 0.12 0.56 6.97 8.57 0.32 3.37 0.89 0.1(0
123,993.0116 19(1,1011 11.11. 0.09 0019 11111 0.64 1.81 3474 I 382.89 5211 49.12 29.51 1100 0.(1u 0110 0.01 2.59 1.21 5.17 382.89 52u11 49.12 1 29.51 0.00 1(0(1
1239F90(0(7' ealetpillm(1340613 1109 1109 0.09 0.91 1.86 41.03 I 40781 55.511 52.32 31.41001 133 1.86 1.3.3 4117.81 55,50 52.32 31.41 00(1 03))
41.113 11X1 11111 11 11111 111111 11190.99 0,119 000
123.63£/1019 Dismal 2191. 0.17 11.17 0.17 0.01 39.64 3,71 66.72 I 795.34 1110.08 94.34 56.67 111111 0.110 0.00 0.30 000 0.17 .17 11.17 11.111 5.,31 3.71 111.61 I 735.34 1(111.118 94.34 56.67 0.011 0.00 999( 0.00 11.011 .00
923,9F3E000 Pti18.IL 0.08 11.08 11118 11111 19.51 1.59 32.84 I 362.00 49.27 4614 2790 0.09 . 0.110 0.1111 9.00 11.10 - 1.00 0.118 098 ((68 (001 2.28 1.59 4.55 362.01( 4927 46.44 27.91) .00 0.011 0.110 11.011 O.IIU 11.1111
I I
I I
Permitted Sources euMolW= 0.44 044 0.44 0.111 120.022 1,686.36 17534 1,888.04 256.% 142.22 7,61938 8,118.58.360.19 3,113.84 6.5306.15 0.00 362.66 0.44 0.44 0.44 0.M 14.73 43.20 40.41 1,88104 256.% 242.22 298.74 16320 5.26 60.84 152659 0.02 7.25
e s s APEX Only-Parma Exempt 8ouree
1 1
APES Only Subtotal= 0.00 0.011 0.00 020 0.00 0.110 600 ; 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.011 0.00 0.00 0.00 0.011 0.00 0.011 0.00 0.91 0.00 0.0)1 0.00 0.00 0.10 0.00 0.00 0.00 0.00 0.00
OPEN Exempt/1m11nmemt sower.
Exempt £x90109 Combustion S,w,um 0.80 11.80uso 1006 111.52 1125 884 I uuo 0.00 . 0.80 0.811 10.52 0.25 8.84 9.00 1001 UM .09 Um 111111 UUII 111111 U16U
E pt 6(0(3710 0.00 0.00 000 000 9.00 0.43 0.00 I 0.110 000 090 1133 1934 17.77 17.91 211.5 (1.11 00 0001 000 0.00 0.00 009 0.43 0.1X1 0.00 0.110 000 18.33 1834 17077 17.91 2095 0.01 0.00
1 -
Iml0oair,mt lahmtal- 0.80 11110 0.80 11.06 10.52 0.68 8.84 I (I.OU 0.00 0.10 1833 18.34 17.77 17.91 10.65 0.00 0.00 0.00 0.111 0.00 0.06 10.52 0.68 8.04 0.00 0.011 0.011 18.33 1134 17.77 17.91 20.65 0.00 0.011
Total„All%mem=I 134 I 1.24 I 1.14 I 0.09 113134 1 1,687.00 1 184.17 11,808.04 1056.06 1102.11 17,657.71 10,136.91 1278.06 13,031.76 1 65327.48 I 0.04 I 362.66 11.14 I 1.24 I 114 I 0.09 125.I5 143.98 I 49.24 186X.04 1256.96 1 242.12 1317.071 182.14 I 23.03 17075 11347.24 10.10 I 7.25
Cnmetrolled HAP.Summary(Pm 0.94 1 0.13 I 0.02 I 3.83 I 4.07 I 0.14 I 1.52 I 32.61 I 0.m I 0.48 I Contmlkd 11AP,901011,(TPV)- 0.94 1 0.13 I 0.12 I 0.16 I 0.09 I 021 1 0.04 I 0.67 10.00 I 0.m
Uncontrolled Total,MI IlAPs PITY) 43.59 I Controlled Total,A11 HAP.(ITV)r] 2.17 I
Footnotes:
I.This Rom should he completed to include 111h existing 9111rccs and all proposed new or modifications to existing emissions sources
2.If the emissions source is new then enter"proposed"under the Permit No.and AIRS II)data columns
3.HAP abbreviations include'.
BZ=Benzene 224-TMP=2,2,4-rimethylpenlane
Tol=Toluene Acelal=Acetaldehyde
EB=Elhylhenzene Acre=Aerolein
Xyl=Xylene n-Her=n-I lexane
HCHO=Formaldehyde Meth=Methanol
4.APEN Exempl/Insignificant Sources should he included whdn warranted.
PDC Energy,Inc. 6/26/2020 - Page 1 of 1
Received August 5, 2020
Condensate Storage Tank(s) APEN,.CForm APCD-205
cDP" Air Pollutant Emission Notice (APEN) and
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 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.
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: 19WE 1020 AIRS ID Number: 123 / 9F3E /001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 1 - Administrative Information
Company Hamel: PDC Energy, Inc.
Site Name: Wiedeman/Boomerang Pad
Site Location
Site Location:
NWNE Sec 5 T5N R66W County: Weld
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-205 - Condensate Storage Tank(s) APEN - Revision 12/2019 1 I ≥�! n""°^` I Xuith b En.onment
Permit Number: 19WE 1020 AIRS ID Number: 123 /9F3E/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 2 - Requested Action
❑ NEW permit OR newly-reported emission source
❑r Request coverage under traditional construction permit
❑ Request coverage under a General Permit
❑ GP01 ❑ 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-
❑✓ MODIFICATION to existing permit (check each box below that applies)
❑ Change in equipment ❑ Change company name3
❑ Change permit limit ❑ Transfer of ownership4 ❑ Other(describe below)
-OR-
❑ APEN submittal for update only(Note blank APENs will not be accepted)
-ADDITIONAL PERMIT ACTIONS-
• 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: APEN Modification to update throughput and convert GP01 to an individual permit.
Previously submitted emission factors have been used
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: Condensate Storage Tanks
Company equipment Identification No. (optional): TK-1
For existing sources, operation began on: 3/22/2017
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: O Exploration It Production (E&P)site O Midstream or Downstream (non E&P)site
Will this equipment be operated in any NAAQS nonattainment area? ❑✓ Yes O No
Are Flash Emissions anticipated from these storage tanks? ❑✓ Yes O No
Is the actual annual average hydrocarbon liquid throughput≥ 500 bbl/day? ❑✓ Yes O No
If"yes", identify the stock tank gas-to-oil ratio: 0.004 m3/liter
Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) ❑✓ Yes ❑ No
805 series rules? If so, submit Form APCD-105.
Are you requesting≥6 ton/yr VOC emissions (per storage tank), or are uncontrolled actual ❑✓ Yes O No
emissions≥6 ton/yr(per storage tank)?
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 12/2019 2 AMP Mobiles Envlso t
Permit Number: 19WE1020 AIRS ID Number: 123 /9F3E/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 4 - Storage Tank(s) Information
Actual Annual Amount Requested Annual Permit Limits
(bbt/year) (bbl/year)
I Condensate Throughput: 1,188,870 1,426,640
From what year is the actual annual amount? 2019
Average API gravity of sales oil: 48.6 degrees RVP of sales oil: 7.7
Tank design: ❑✓ Fixed roof 0 Internal floating roof ❑ 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 10 4,000 2/2017 3/2017
Wells Serviced by this Storage Tank or Tank Battery6(E&P Sites Only)
API Number Name of Well Newly Reported Well
05 - 123 - 40063 SRC Wiedeman 22-5-4NBHZ ❑
05 - 123 - 40064 SRC Wiedeman A-5-3NBHZ ❑
05 - 123 - 40065 SRC Wiedeman 12-5-4CHZ 0
05 - 123 - 40066 SRC Wiedeman 11-5-3NCHZ O
05 - 123 - 40067 SRC Wiedeman 22-5-4CHZ ❑
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 The EEtP Storage Tank APEN Addendum (Form APCD-212)should be completed and attached when additional space is needed to
report all welts that are serviced by the equipment reported on this APEN form.
Section 5 - Geographical/Stack Information
Geographical Coordinates
(Latitude/Longitude or UTM)
40.43311 /-104.801741
❑ 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.
Operator Stack Discharge Height Above Temp. Flow Rate Velocity
ID No. Ground Level(Feet) (°F)_ (ACFM) (1t/sec)
(4)IES 27.25 1,076 451.4 0.19
Indicate the direction of the stack outlet: (check one)
El Upward O Downward O Upward with obstructing raincap
❑Horizontal O Other(describe):
Indicate the stack opening and size: (check one)
El Circular Interior stack diameter(inches): 85.5
❑Square/rectangle Interior stack width (inches): Interior stack depth (inches):
❑Other(describe):
y!► COLORAD
O
Form APCD 205 Condensate Storage Tank(s) APEN Revision 12/2019 3 I �! '�`"°"`""�""`
Health 6 Hnre4onment
Permit Number: 19WE 1020 AIRS ID Number: 123 /9F3E/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID
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:
Vapor Size: Make/Model:
❑ Recovery
Unit (VRU): Requested Control Efficiency:
VRU Downtime or Bypassed (emissions vented): %
Pollutants Controlled: VOC & HAPs
Rating: 269.62 MMBtu/hr
Type: Enclosed Combustors Make/Model: 4 x IES 96"
❑ Combustion Requested Control Efficiency: 98
Device:
Manufacturer Guaranteed Control Efficiency: 98
Minimum Temperature: 1,076 F Waste Gas Heat Content: 2,490 Btu/scf
Constant Pilot Light: ❑✓ Yes ❑ No Pilot Burner Rating: 0.061 MMBtu/hr
Description of the closed loop system:
❑ Closed Loop System
Pollutants Controlled:
❑ Other: Description:
Control Efficiency Requested: %
Section 7 - Gas/Liquids Separation Technology Information (E£tP Sites Only)
What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 19 psig
Describe the separation process between the well and the storage tanks:
(24) Horizontal 48" Leed Separators, (4)Vertical Knockout Separators, (1) Worthington 60" Gasbuster
COLORADO
Form APCD-205 Condensate Storage Tank(s) APEN - Revision 12/2019 4
Permit Number: 19WE1020 AIRS ID Number: 123 i 9F3E/001
[Leave blank unless APCD has already assigned a permit#and AIRS ID]
Section 8 - Criteria Pollutant Emissions Information
Attach all emissions calculations and emission factor documentation to this APEN form7.
Is any emission control equipment or practice used to reduce emissions? ❑✓ Yes 0 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)
VOC Enclosed Combustors 100% 98
NOx
CO
HAPs Enclosed Combustors 100% 98%
Other:
From what year is the following reported actual annual emissions data? 201 9
Use the following table to report the criteria pollutant emissions from source:
Emission Factor? Actual Annual Emissions Requested Annual Permit
Pollutant Emission Limit(s)5
Uncontrolled Source Uncontrolled Controlled Uncontrolled Controlled
Basis Units (Ap a2, Emissions Emissions$ Emissions Emissions
Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year)
VOC 1.8775 lb/bbl ProMax 1,116.05 22.32 1,339.26 26.79
NOx 0.0680 Ib/MMBtu AP-42 N/A 2.10 N/A 2.52
CO 0.3100 Ib/MMBtu AP-42 N/A 9.57 N/A 11.47
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.
7 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.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
Section 9 - Non-Criteria Pollutant Emissions Information
Does the emissions source have any uncontrolled actual emissions of non-criteria Yes 0 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
Chemical Name Source Uncontro Controlled
Service(CAS) Uncontrolled Units (AP-42, Emissions Emissions
Number Basis Mfg.,etc.) (lbs/year) (lbs/year)
Benzene 71432 4.07E-03 lb/bbl ProMax 5,606.42 96.77
Toluene 108883 4.43E-03 lb/bbl ProMax 6,320.02 105.33
Ethylbenzene 100414 1.41E-04 lb/bbl ProMax 201.15(DM) 3.35
Xylene 1330207 1.64E-03 lb/bbl ProMax 2,339.69 38.99
n-Hexane 110543 3.67E-02 lb/bbl ProMax 52,362.19 872.71
2,2,4-Trimethylpentane 540841 2.07E-04 lb/bbl ProMax 295.31 4.92
7 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.
8 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide
projected emissions.
COLORADO
Form APCD-205 - Condensate Storage Tank(s) APEN - Revision 12/2019 5 I """"""nmen 1Sm�lt�6 rnVl[OIImOn{
Permit Number: 19WE1020 AIRS ID Number: 123 i 9F3E 1 001
[Leave blank unless APCD has already assigned a permit aa`and AIRS ID)
Section 10-Applicant Certification
I hereby certify that alt 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 wilt be operated in full compliance with each condition of the applicable General Permit.
1.c/t4- -.._----- '(a le
4/2-CI
n D
Sign ure of Legally Authorized Person(not a vendor or consultant)
Jack Starr Senior Air Quality Representative
Name(print) Title
Check the appropriate box to request a copy of the:
Draft permit prior to issuance
Q 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
R
OR
Air Pollution Control Division (303)692-3148
APCD-SS-BI
4300 Cherry Creek Drive South APCD Main Phone Number
Denver,Co 80246-1530
(303)692-3150
Make check payable to:
Colorado Department of Public Health and Environment
COLORADO
Form APCD-2O5 Condensate Storage Tank(s)APEN-Revision 12/2019 6 I
w�ras
Company Name: PDC Energy,Inc.
Facility Name:Wiedeman/Boomerang Pad
Condensate Storage Tank Emissions Calculations
Actual Production(bbl/yr): 1,188,870 Actual Production While Controls Operational(bbl/yr): 1,188,870
Requested Production(bbllyr): 1,426,640 Requested Production While Controls Operational(bbl/yr): 1,426,640
Actual Flash gas(MMBtu/yr): 61,206.25
Pollutant Emission Factor EF Units Control Actual Uncontrolled Actual Controlled Requested Requested
Efficiency Uncontrolled Controlled
VOC(TPY) 1.8775 Ib/bbl 98.00% 1116.05 22.32 1339.26 26.79
NOx(TPY) 0.0680 Ib/MMBtu 98.00% N/A 2.08 N/A 2.50
CO(TPY) 0.3100 lb/MMBtu 98.00% NIA 9.49 N/A 11.38
Benzene(Ib/yr) 4.07E-03 lb/bbl 98.00% 5806.42 96.77 5806.42 116.13
Toluene(Ib/yr) 4.43E-03 lb/bbl 98.00% 6320.02 105.33 6320.02 126.40
Ethylbenzene(Ib/yr) 1.41E-04 lb/bbl 98.00%. 201.15 3.35 201.15 4.02
Xylene(Ib/yr) 1.64E-03 lb/bbl 98.00% 2339.69 38.99 2339.69 46.79
n-Hexane(lb/yr) 3.67E-02 lb/bbl 98.00% 52362.19 872.71 52362.19 1047.24
2,2,4-TMP(lb/yr) 2.07E-04 lb/bbl 98.00% 295.31 4.92 295.31 5.91
Production forecasts are based on the first thirty(30)days of production for new wells. The average daily production rate from those first thirty(30)days is then multiplied by
365 to achieve an annualized production value. This annualized production value then has the default decline factor of 60%'applied to forecast the first 12 months of production
from those new wells.
Production for existing wells is forecasted using a daily average that is annualized based on the most current data available.
Production while controls operational represents a portion of this facility's production where the tank emissions were uncontrolled.
1-Decline Factor of 60%-PS Memo 05-01"Oil B Gas Condensate Tank Batteries Regulatory Definitions and Permitting Guidance"
NOx and CO emission factors were taken from Table 4 of the Texas Natural Resource Conservation Commission's(TNRCC)"Air Permit Technical Guidance for Chemical Sources-
Flares and Vapor Oxidizers"document(shown as'TCEQ'on any associated APENs). The waste gas stream is assumed to be high-Btu(>1,000 Btu/scf).
Site Specific Emission Factors have been used to calculate emissions.
Example Calculations: ( 1 r
Uncontrolled Emissions I !b J=Annual Uncontrolled Throughput bbl)•Emission Factor lb
yr l yr J bbl
1T'ank VRU Control Efficiency = U— VRU Downtime c/o)• WW1;Capture/Control Efficiency)
'orttroi Efficiency=1—(U—Tank VRU Control Efficiency) 'a-ECD Contra(Efficiency))
Controlled Emissions I yr J=Annual Controlled Throughput)ybl J•Emission Factor bbl) (1—Control Effciency)
yl +Annual Uncontrolled Throughput Yblr)•Emission Factor bbl
tons lb lion
VOC Emissions =Emissions —
yr yr f 2,000/h
Flash Gasl MMBtuj=
ll yr r11
UncontrolkdVOCI yn1 2,000/bl 1 1 r379.41SCFGasI ( l e 1.HeatContenQ Btu) (1MMBtu)
VOC(—
yr ton I Gas MW l lb—mol ) IVOC/o) ISCF) 106 Btu J
o lb MMBtu lion
NOx&C(.)( -21 )=Emission Factor Flach Gasyr �MMBtu� yr 12000/b)
NOTE: Flash gas heat content,molecular weight and VOC fraction are based on ProMax 4.0 emission simulation.
Company Name:PDC Energy,Inc.
Facility Name:Wiedeman/Boomerang Pad
Condensate Tank Pilot Light Emissions Calculations
Actual Fuel Requested Fuel Annual Fuel Fuel Htg Emission Factors Actual Pilot Emissions Requested Pilot Emissions
Reference Consumption Consumption Op Time Type Value NOx' CO' VOC 2 NOx CO VOC NOx CO VOC
ID scf/hr scf/hr (hours) (Btu/scf) (Ib/MMBtu) (Ib/MMBtu) (lb/MMscf) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY) (lb/hr) (TPY)
Tank Combustor 1 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Tank Combustor 2 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Tank Combustor 3 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Tank Combustor 4 12.50 12.50 8760 Field 1216 0.068 0.310 6.130 0.00 0.00 0.00 0.02 0.00 0.00 0.00 0.00 0.00 0.02 0.00 0.00
Total Emissions: 0.00 0.02 0.02 0.08 0.00 0.00 0.00 0.02 0.02 0.08 0.00 0.00
Actual Controlled Requested Controlled
NOx CO VOC NOx CO VOC
Combustor Pilot Light Emissions 0.02 0.08 0.00 0.02 0.08 0.00
Tank Emissions 2.08 9.49 22.32 2.50 11.38 26.79
Total Emissions 2.10 9.57 22.32 2.52 11.47 26.79
1-NOx and CO emission factors from AP-42 Table 13.5-1 Emission Factors for Flare Operations
2-VOC emission factor from AP-42 Table 1.42 Emission Factors for Criteria Pollutants and Greenhouse Gases From Natural Gas Combustion
Example Calculations:
Emissions(lb/hr)=EF(Ib/MMBtu)*Fuel Consumption(scf/hr)•Fuel Htg Value(Btu/scf)*1 MMBtul1x10 'Btu
Emissions(lb/hr)=EF(Ib/MMscf)*Fuel Consumption(scf/hr)*1 MMscf/1x10 'scf
Emissions(TPY)=Emissions(lb/hr)•Annual Operating Time(hrlyr)•1 ton/2000 lb
Colorado Department of Public Health and Environment
Form APCD-102 Air Pollution Control Division G D P H E
`'
Facility Wide Emissions Inventory Form
Ver.April,2(115 ;jam R
Company Name:PDC Energy,Inc
Source Name:Wiedeman/Boomerang Pad
Source MRS ID:123/9F3E
Uncontrolled Po0old to Emit(PPE) Controlled Puteoll(T d lo Emit(PPE)
rikriu(1'PY) I IIAP,(1X111) Criteria OTT) HAP"(Ibcyr)
AIRS10 Egdptoeaoescripion T7P •• P502.5C S()2 -NOs VOC CO I HCHO 1181+1 Aare HZ Tol -EB Syl n-Iler 51,01. 224-1 NIP TSP 17610 PM112.5 SO2 0111 NOS. 00 HCHO Met, Aero B0 Toll El .1)0 -1310.1 Mob 214-ThrP
1239(32,091 Cmdauenc Tads 1.339.26 0.1(0 I am cup 0.00 5,806.42 6,320.112 201.15 2.33)69 52.362.19 0.0 295.31 999 152 26.79 11.47 0.(10 0310 11.011 116.13 126.40 4.02 4679 10147.2) 0.00 591
(23.9(3(0115 Comizna.Lnednl 9.00 0.00 01(0 0.119 0.09 29.67 OM 0.00 090 0.00 -7200 090 0.911 0.00 6324] 003 (03 0.12 93111 0.00 0.00 3162
(2/332,0(13 Ihodeed Watc'fonks 0.0 11.110 (1.11(1 0.011 0.11(1 1210 0.00 I 292.42 359.77 1335 14137 37308 0.00 090 0.12 5.90 0.56 7.112 863 3.40 8.95 11.00
0.1111
(2/9F70009 Duumn11.1L 1399 1,01 20.04 1.61 3374 I 382.89 52.101 49.12 29.51 0.00 . 0.09 0,91 259 1.81 5.17 322.89 52.11 49.112 29.51 11.00 0,00 0.00 9.1111 000 900
123.903(1197 Caterpillwl;l496TA 1(.01 41113 0.86 4111.3 I 407.81 5550 52.32 31.43 001 133 1.86 5.33 407.81 55.50 5232 31.43 0.011 11.99 DU 0.1111 0.00 0.00
127963(.019 Duman 21.95 0.17 (1.17 0.11] 1.01 39.64 3.71 66.72 1735.34 100.98 94.34 50.67 0.1010.90 011 0.17 0,17 901 3.71 111 7.96 73534 1(1(1.08 0434 56.67 0.00 0,00 0.00 0.00 111111 011 11
12119(30/0118 031 8.15 0.08 10.08 11.118 001 19.51 1.59 32843 362.00 49.27 46.44 27.90 000 03111 0.00 9.00 0.00 0.00 0.08 0.08 008 0.91 2.28 1.59 4.55 362.00 49.27 46.44 27:911 0.90 11.00 11.011 0.00 0109 0.00
Perr4004 Sources 500101.0- 0.44 0.44 044 0.01 120.82 1381.01 115.341 1,808.04 256.96 242.22 6,11].24 1,659.79 214.51 2,481.26 53)67.75 0.011 295.)1 0.44 11.44 11.44 0.111 12.57 42.70 15.16 1,888.04 256.96 142.22 2]231 135.01 434 50.19 1,087.02 0.100 5.91
APEN Only-Perm.Exempt Sources
APEN Only Subtotal= 0.00 0.110 0.110 0.00 0,00 0.00 0.00 I 0.00 0.00 0.00 0.110 10.010 0.1111 0.011 0.010 0.100 0.00 0.00 0.00 0.00 0.1011 0.1111 0.00 0.00 I 0.00 1(.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.110
APES Exempt/Im02osnrod source+
0mmp E,3e,nal Combustion Suurwn 0.06 1052 0.25 784 I0.00 9.811 ., 10.52 0.25 8.84 1 9.00 11.110 111101 11.101 0.00 0011 11110 1110 1811 Ir 111111 p110 0.1111
Exempt Fugitives 11.1111 11.110 0.011 11.1111 0.011 043 0.110 1 000 (lOU 11.1111 18..33 1834 17.]7 17.91 2065 0.11(1 11.911 11.111 01.001 11.11 009 41101 043 0.00 I 000 9.00 9(9) 18,33 18.34 17]7 17.91 211.65 1.1111 0(91
I 1
I I
',o kd0)ant Subtotal= 0.80 0.80 11.80 0.106 10.52 0.60 0.04 I 0.00 0,00 0.00 18)3 18.14 17.77 17.91 20.65 0.010 0.00 0.00 0.80 0.80 0.06 10.52 0.68 8.84 I 0.00 0.00 10.00 18.31 18.14 17.77 17.91 20.65 0.00 0.00
TOO,AU Sources- 134 I 1.24 I 134 I 0.09 113134 11381.701 184.17 1 0.20004 1156.96 1242.22 1 6335.57 1 6,590.111 211.20 12,499.17 15)38040 I 0.00 I 19531 1124 I 1.24 I 1.24 I 0.09 123.09 14338 I 41.99 1 1,888.04 1256.96I 242.21 1290.64 115537 I 22.02 16010 I 1,101147 10.00 I 5.91
11,,,00010001 HAP,51®mry(TPY)-I 0.94 I 0.11 I 0.01 I 3.17 I 335 I 0.02 I 135 1 26.69 I 0.00 I 0.15 I eemrol4d 0,51'.Smnmary(TPV)=1 0.94 I 0.13 I 0.11 I 0.15 I 0.00 I 0.01 I 0.01 J 0.55 10.00 I 0.00
Ilnronaelkd Totd,AO HAPs(TPY)=I 15.92 I Controlledl'otd,All 11APs(TOO-F 2.02 I
Footnotes:
I.This form should be completed to include both existing 01076es and all proposed new or modifications to existing emissions sources
2. If the emissions source is new then enter"proposed"undo the Permit No.and AIRS II)data columns
3.I LAP abbreviations include:
BZ=Benzene 224-IMP=2,2.4-Trimethylpentane
Tol=Toluene Acetal=Acetaldehyde
EB=Iithylhenzene Acre=Acrolein
Xyl=Xylene n-Hex=n-Hexane
HCHO=Formaldehyde Meth=Methanol
4.APEN Exempt/Insignitiuont Sources should be included when warranted.
PDC Energy,Inc. 8/5/2020 Page 1 of 1
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