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HomeMy WebLinkAbout20203731.tiff Cw x -r• COLORADO RECEIVED Department of Public Nte 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 PDC Energy, Inc - Wiedeman Federal 22 Sec HZ. A copy of this public notice and the public comment packet are enclosed. Thank you for assisting the Division by posting a copy of this public comment packet in your office. Public copies of these documents are required by Colorado Air Quality Control Commission regulations. The packet must be available for public inspection for a period of thirty (30) days from the beginning of the public notice period. Please send any comment regarding this public notice to the address below. Colorado Dept. of Public Health Et Environment APCD-SS-B1 4300 Cherry Creek Drive South Denver, Colorado 80246-1530 Attention: Public Notice Coordinator ` 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe I `4i :4,;,-,` � Jared Polls, Governor I Jill Hunsaker Ryan,MPH, Executive Director .I ).'; Pu b I; c Re v;e(, ) cc:pt..cro HLtbs/ra),PW(VKIER/c.H/co 2020-3731 12 123/2O ta.hslao 414 C'''' .�,M Air Pollution Control Divisio n nNotice of a Proposed Project or Activity Warranting Public CDPHE Comment Website Title: PDC Energy, Inc - Wiedeman Federal 22 Sec HZ - 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: PDC Energy, Inc Facility: Wiedeman Federal 22 Sec HZ Well Production Facility NWNW quadrant of Section 22, Township 4N, Range 66W Weld County The proposed project or activity is as follows: PDC Energy, Inc wishes to reduce requested permitted emissions by reducing requested condensate throughput. 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 18WE0854 have been filed with the Weld County Clerk's office. A copy of the draft permit and the Division's analysis are available on the Division's website at https://www.colorado.gov/pacific/cdphe/air-permit-public-notices The Division hereby solicits submission of public comment from any interested person concerning the ability of the proposed project or activity to comply with the applicable standards and regulations of the Commission. The Division will receive and consider written public comments for thirty calendar days after the date of this Notice. Comments may be submitted using the following options: • Use the web form at https://www.colorado.Rov/pacific/cdphe/air-permit-public-notices. This page also includes guidance for public participation • Send an email to cdphe.commentsapcd@state.co.us • Send comments to our mailing address: Diego Chimendes Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 Denver, Colorado 80246-1530 je,,...... COLORADO Department of Public 1 I °P Health Et Environment CCOLORADO VIle Air Pollution Control Division Department of Public Health b Eneronment Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 18WE0854 Issuance: 2 Date issued: XX/XX/XXXX Issued to: PDC Energy, Inc. Facility Name: Wiedeman Federal 22 Sec HZ Plant AIRS ID: 123/9FE5 Physical Location: NWSW SEC 22 T4N R66W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Equipment Description ID Point Description Ten (10) 538 barrel fixed roof liquid TK-1 001 manifold storage vessels`used to store Enclosed Combustors condensate. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the,conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or Page 1 of 9 COLORADO Air Pollution Control Division Department of Public Health 8 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 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: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type TK-1 001 --- 2.0 22.9 4.2 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 criteria pollutants must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 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 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 Control Device Pollutants Equipment ID Point Controlled TK-1 001 Enclosed Combustor VOC and HAP Page 2 of 9 r, COLORADO • Air Pollution Control Division Department of Public Health Ft Environment Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 7. 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 Process Process Parameter Annual Limit Equipment ID Point 01 Condensate Throughput 170,247 barrels TK-1 001 02 Combustion of pilot 1.5 MMscf light gas The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. STATE AND FEDERAL REGULATORY REQUIREMENTS 8. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.)I.E.) (State only enforceable) 9. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 10. 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) 11. 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 Page 3 of 9 �C :•;: 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 equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 12. 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. 13. 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. 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING a MAINTENANCE REQUIREMENTS 15. Upon startup of these points, the owner or operator must follow the most recent operating and maintenance (OEM) 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 OEtM plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 18. All previous versions of this permit are cancelled upon issuance of this permit. 19. 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: Page 4 of 9 rY 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 For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOr) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. 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 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation Page 5 of 9 .Y: COLORADO 41 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: DRAFT Diego Chimendes Permit Engineer Permit History Issuance Date Description Issuance 1 July 30, 2019 Issued to PDC Energy, Inc. Issuance 2 This Issuance Issued to PDC Energy, Inc. Operator reduced permitted emissions by reducing requested condensate throughput. Page 6 of 9 a ,i.,.- COLORADO >4"4OIII Air Pollution Control Division Department of Public Health b 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 2657 133 Toluene 108883 3904 195 Ethylbenzene 100414 79 4 001 Xylenes 1330207 1231 62 n-Hexane 110543 23290 1165 2,2,4- 540841 40 2 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year(lb/yr) are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Process 01: Condensate Throughput Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 2.326x10-2 2.326x10-2 TNRCC and Promax CO 4.644x10-2 4.644x1O2 TNRCC and Promax Page 7 of 9 1,..,... COLORADO COLORADO 41 Air Pollution Control Division Department of Public Health&Environment Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl V0C 5.3699 2.6850x10-t Promax 71432 Benzene 1.560x10-2 7.802x10-4 Promax 108883 Toluene 2.293x10-2 1.467x10-3 Promax 1330207 Xylene 7.231x10-3 3.616x10-4 Promax 110543 n-Hexane 1.368x10-1 6.840x10-3 Promax Note: The controlled emissions factors for this point are based on a control efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the Wiederman Federal 22H-402 well on 07/16/2018. The NOx and CO TNRCC emission factors(0.1380 lb/MMBtu and 0.2755 lb/MMBtu respectively) were converted to units of lb/bbl using a heat content of 2570.5 Btu/scf, molecular weight of 46.2 lb/lbmole, a standard molar volume of 379.41 scf/lb-mole, and a VOC mol%of 67.24%. Actual emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput. Process 02: Combustion of pilot light Uncontrolled Emission CAS # Pollutant Factors Source lb/MMSCF N0x 77.2 AP-42 Chapter 13.5 V0C 6.1 AP-42 Chapter 1.4 Table 1.4-2 CO 352.2 AP-42 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 1,136 Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4 emission factor by a heat value of 1,136 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 15.6 scf/hr. There are a total of eleven (11) combustors used to control emissions from the condensate storage vessels. As a result, the total pilot light gas fuel flow is 171.6 scf/hr. 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: Applicable Status Requirement Page 8 of 9 ' 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 Operating Permit Synthetic Minor Source of: VOC, NOx and n-Hexane. True Minor Source of CO. PSD True Minor Source of: CO. NANSR Synthetic Minor Source of: VOC and NOx. MACT HH Area/Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecf r.goy/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End ' Subpart NNNNN - Subpart XXXXXX Page 9 of 9 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Diego Chimendes Package#: 434232. Received Date: 7/31/2020 Review Start Date: 111/3/2020 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section Township Range County AIRS ID: 123 NWSW 22 4N 66 Plant AIRS ID: 9FE5 Facility Name: Wiedeman Federal 22 Sec HZ Physical Address/Location: NWSW quadrant of Section 22,Township 4N,Range 66W County: Weld County Type of Facility: Exploration&Production Well Pad_ What industry segment?Oil&Natural Gas Production&Processing Is this facility located in a NAAQS non-attainment area? Yes If yes,for what pollutant? Ozone(NOx&VOC) Section 02-Emissions Units In Permit Application Leave Blank-For Division Use Only AIRs Point# Permit# Emissions (Leave blank unless Issuance Self Cert Engineering (Leave blank unless APCD Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks has already assigned) assigned) Permit 001 Storage Tank TK-1 Yes 18WE0854 2 Yes Modification Section 03-Description of Project PDC Energy,Inc.(PDC)submitted an application requesting modification of permit 18WE0854.PDC wishes to reduce requested permitted emissions by reducing requested condensate throughput. This point source is APEN-required because uncontrolled VOC emissions are greater than 1 tpy and uncontrolled emissions of at least one non-criteria pollutant is greater than 250 tpy.(Regulation 3 Part A Section 11.8.3.)Point source is permit-required because uncontrolled facility-wide VOC emissions are greater than 2 tpy. (Regulation 3 Part B Section 11.0.2.). This point source is subject to public comments because source is attempting to obtain a federally enforceable limit on the potential to emit of the source in order to avoid other requirements.(Regulation 3 Part B Sections III.C.1:d.). Point source is not subject to ambient air impact analysis.(Regulation 3 Part D Section II.A.44). Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requirement Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No - Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) _ Title V Operating Permits(OP) ✓ J ❑J Non-Attainment New Source Review(NANSR) ✓ ✓ Is this stationary source a major source? No Colorado Air Permitting Project If yes,indicate programs and which pollutants: 5O2 NOx CO VOC. PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) Title V Operating Permits(OP) Non-Attainment New Source Review(NANSR) Storage Tar(s)Fnmissior.s Inventory Section 01-Administrative Information 123 9FES 001 Facility Allis ID: County Plant Point Section 02-Equipment Description Details Storage Tank Liquid Condensate Detailed Emissions Unit Ten(10)538 barrel fixed roof liquid manifold storage vessels used to store condensate. Description: Emission Control Device Ten(10)Cimarron 48".&one(1)Cimarron 60"enclosed combustors. Description: Requested Overall VOC&HAP Control Efficiency%: 95.0. Limited Process Parameter y�' " a2`P Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Storage Tanks) Actual Throughput= 170,2474.Barrels(bbl)per year 'Requested Permit Limit Throughput= ti 'xAyMIN'17f,247i4,Barrels(bbl(per year Requested Monthly Throughput= 14459.3 Barrels(bbl)per month Potential to Emit PTE Condensate Throughput ,,( I '�456n,,es7,!0,337 Q Barrels(bbl)per year Secondary Emissions-Combustion Device(s) Heat content of waste gas= :.2570.5 Btu/scf Volume of waste gas emitted per BBL of liquids produced= scf/bbl Molecular Weight= 46.2 Ib/Ibmol VOC mol%= 67.24% Molar Volume= 379.4 scf/Ibmol Actualheatcontentofwastegasroutedtocombustiondevice= 28,697.9 MMBTU per year Requested heat content of waste gas routed to combustion device= 28,697.9 MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= 28,697.9 MMBTU per year Control Device Pilot Fuel Use Rate: ri 171 6 scfh 1.5 MMscf/yr 13 Pilot Fuel Gas Heating Value: '{4 „,s•�f336�Btu/scf 1707.7 MMBTU/yr Section 04-Emissions Factors&Methodologies k Will this storage tank emit flash emissions? ,.�e�„'� , Emission.Factors Condensate Tank Uncontrolled Controlled Pollutant (16/60) (lb/bbl) Emission Factor Source (Condensate (Condensate Throughput) Throughput) VOC 5.3699E+00 2.6850E-01 Site Specific E.F.(includes flash) Benzene 1.560E-02 7.802E-04 Site Specific E.F.(includes Flash) Toluene 2.293E-02 1.147E-03 Site Specific E (inciudes flash) Ethylhenzene 4.666E-04 2.333E-05 Site Specific Er(includes flash) Xylene 7.231E-03 3.616E-04 Site Specific E F-(includes flash) n-Hexane 1.368E-01 6.840E-03 Site Specific C.F.(includes flash) 2Z4TMP 2.355E-04 1.177E-05 Site Specific E.F.(includes flash) Control Device Uncontrolled Uncontrolled Pollutant _ )lb/MMBtu) (lb/bbl) Emission Factor Source (waste heat (Condensate combusted) Throughput) PM10 0.0075 1.256E-03 AP-42 Table 1.4-2(PM10/PM.2.5) :. PM2.5 0.0075 1.256E-03 AP-42 Table 1.4-2(PM10/PM.25) 500 0.0006 9.916E-05 Other-Explain NOx 0,1380 2.326E-02 TNRCC Flare Emissions Guidance(Nan) CO .9,2755 4.644E-02 TNRCC Flare Emissions Guidance(CO) Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MMBtu) (Ib/MMscf) Emission Factor Source(Pilot Gas Heat (Pilot Gas Combusted) Throughput) PM10 0.0075 8.5 Ap.42 Tabl 1.4-2(PM10/PM.25) PM2.5 0.0075 8.5 AP:42 Tabs 1.4-2(PM10/PM.2 5) 50x 0.0006 0.7 AP-42 Table 14-2(SOx). NOx 0.0680 77.2 AP-42 Chapter 135 Industrial Flares iN0x) VOC 0.0054 - 6.1 AP-42 Table 1.4-2(VOC) CO 0.3100 352.2 AP-42 Chapter 13.5 Industrial Flares(CO) grl. Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tons/year) (tons/year) (tons/year) (tons/year) (tons/year) (lbs/month) PM10 0.1 0.1 0.1 0.1 0.1 19.2 PM2.5 0.1 0.1 0.1 0.1 0.1 19.2 SOx 0.0 0.0 0.0 0.0 0.0 1.5 NOx 2.04 2.04 2.04 2.04 2.04 346.2 VOC 457.11 457.11 22.86 457.11 22.86 3883.0 CO 4.22 4.22 4.22 4.22 4.22 716.5 3 of 9 K:\PA\2018\18WE0854.CP2 Storage Tank(s)Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Ps/year) (Ibs/year) (Ibs/year) (Ibs/year) (lbs/year) Benzene 2656.5 2656.5 132.8 2657 133 Toluene 3904.0 3904.0 195.2 3904 195 • Ethylbenzene 79.4 79.4 4.0 79 4 Xylene 1231.1 1231.1 61.6 1231 62 n-Hexane 23290.2 23290.2 1164.5 23290 1165 224 TMP 40.1 .40.1 2.0 40 2 4 of 9 K:\PA\2018\18WE0854.CP2 Storage Took(s)Emissions inventory • Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Source requires a permit Regulation 7,Part D,Section I.C,D,E,F Storage tank is subject to Regulation 7,Part 0,Section I.C-F Regulation 7,Part D,Section I.G,C Storage Tank is not subject to Regulation 7,Section I.G Regulation 7,Part D,Section II.B,C.1,C.3 Storage tank is subject to Regulation 7,Part 0,Section II,B,C.1&C.3 Regulation 7,Part 0,5ection II.C.2 Storage tank is subject to Regulation 7,Part D,Section II.C.2 Regulation 7,Part D,5ection II.C.4.a.(i) Storage Tank is not subject to Regulation 7,Part D,Section II.C.4.a(i) Regulation 7,Part D,Section II.C.4.a.(ii) Storage Tank is not subject to Regulation 7,Part D,Section II.C.4.alii),b-f Regulation 6,Part A,NSPS Subpart Kb Storage Tank is not subject to NSPS Kb Regulation 6,Part A,N5FS Subpart 0000 Storage tank is not subject to NSPS 0000. NSPS Subpart 00000 Storage Tank is not subject to NSPS 0000a Regulation 8,Part E,MAC]Subpart HH Storage Tank is not subject to MACT HH (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements For condensate or crude oil tanks,does the company use the state default emissions factors to . '" T ss estimate emissions? If yes,are the uncontrolled actual or requested emissions for a crude oil tank estimated to be greater than or equal to 20 tons ROC per year OR are the uncontrolled actual or requested emissions for a condensate storage tank estimated to be greater than or equal to 80 tpy? If yes,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company use a site specific emissions factor to estimate emissions? If yes and if there are flash missions,are the emissions factors based on a pressurized liquid sample drawn at the facility being , p, permitted(for produced water tanks,a pressurize liquid sample must be analyzed using flash iberat on analysis)?This sample should be considered representative which generally means site-specific and collected within one year of the application received ',i` ,r date However,if the facility has not been modified(e.g.,no new wells brought on-line),then it maybe appropriate to use n ,' older site-specific sample. Yes/ " .,vi*Au: y If no,the permit will contain an"Initial Compliance"testing requirement to develop a site specific emissions factor based on guidelines in PS Memo 14-03. Does the company request a control device efficiency greater than 95%for a flare or combustion deuce? •1 _4,„,K s` If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 08-Technical Analysis Notes 1.Site-specific Emission Factors:The site specific sample used to establish emissions factors for this source was obtained within a year of the first issuance application.The sample was obtained from theWiederman Federal 228-402 welt.This well is one of the ten(10}wells drilled at this facility and there were no significant changes to the facility ince the development of the emissions factors.Asa result,the permit will not require initial testing in order to obtain a new site specific sample.It should be noted that the sample includes sample prdre temperature and pressure in conjunction with gauge pressure and temperature. 2.Secondary Emissions Calculations: 2.1 Operator used the following equation to calculate the annual heat input. Heat Input(MMBtu/yr)_[Uncontrolled VOC(ton/yr)].[2000(lb/tort)]_MW(lb/lbmo1).[379.41(scf/IbmoI)].[1/VOC mot%]+[Heat Content(Btu/scf)].[1MMBtu/(1000,000 Btu)]. The values used in the equation were obtained from a Pro Max simulation used to calculate emissions and develop emission facto-.The values used are as follow:(i)Molecular weight:46.2 lb/Ib-mol,(ii)VOC mot%: 67.2%,(iii)Heat Content:2570.51 Btu/scf. - - 3.Pilot Light Emissions Calculations;Operator assumed pilot fuel to have the same conditions of field gas which is consistent with the plant design provide by operator.The permit will not contain initial or periodic opacity testing for the enclosed combustor(s)because the 0&M plan approved for this source requires weekly visible emissionsobservations of the enclosed combustor(s(..A throughput limit is included in the permit for pilot combustion Emission factors and calculation methods for pilot light combustion emissions are also included in thenotes to permit holder.This information is included in the permit because pilot light emissions contribute to the overall emissions from this source.Additionally S is important to include this information became throughput tracking and emission calculation methods are different than those used to estimate emissions based on the condensate throughput.This clarity a important for accurately quantifying actual emissionsat this facility. 4.Operator submitted self-certification on 01/24/2020.Division approved self-certification on 02/13/2020. S.Permit draft was provided,to operator on 11/23/2020.Operator provided one comment about the name of the facility which was corrected. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only) . Uncontrolled Emissions AIRS Point# Process# SCC Code Pollutant Factor Control% Units 001 01 4-04-003-11 Fixed Roof Tank,Condensate,wofking+breathing+0ashinglosses PM10 0.03 0 lb/1,000 gallons Condensate throughput PM2.5 0.03 0 lb/1,000 gallons Condensate throughput 50x #REF! 0 lb/1,000 gallons Condensate throughput NOx 0.57 0 lb/1,000 gallons Condensate throughput VOC 127.86 95 lb/1,000 gallons Condensate throughput CO 1.18 0 lb/1,000 gallons Condensate throughput Benzene 0.37 95 lb/1,000 gallons Condensate throughput . Toluene 0.55 95 lb/1,000 gallons Condensate throughput Ethylbenzene 0.01 95 lb/1,000 gallons Condensate throughput Xylene 0.17 95 lb/1,000 gallons Condensate throughput n-Hexane 3.26 95 lb/1,000 gallons Condensate throughput 224 TMP 0.01 95 lb/1,000 gallons Condensate throughput 5 of 9 K:\PA\2018\18W E0854.CP2 Storage Tank Regulatory Analytic Worksheet The regulatory requirements below ore determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Cnn ATTAINMENT 1. Are uncontrolled actual emissions from any criteria polhrtants from this individual source greater than 2TPY(Regulation 3,Part A,Section ll.0.le)? Source Requires an APEN.Go to 2 Is the tuctl date(service date)prior to not modified after 12/31/2002(See PS Memo 05-01 Definitions 1.12 and114 and Seaton 2 far additional guidance on grandfather applicability)? Go to next question 3 Are total f cility uncontrolledYe: I greater than 5TPY,NOxgreater than 10 TPY or CO emissions greater than 10TPY(Regulation 3,Part e,Section 11.0.3)? Source Requires a permit NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Repletion 3,Part A,Section ll.D.l.a)? 41.46/&/�_Source Requires an APEN.Go to 2. is the construction date(service date)prior to 12/30/2002 and not modified after 12/31/2002(See PS Memo 0501 Definitions 1.12 and1.14 and Section 2for additional guidance on grandfather applicability)? Jr:76 Goto next queson 3. Are total facility uncontrolled VOL emissions greater than 2TPY,NON greater than 5TPY or CO emissions greater than tOTFY(Regulation 3,Parte,Section 11.0.2)? .Y(/'-ip,-3 Source Requires a permit I Colorado Regulation 7.rPart O,Section I,C-F'&G 1. Isthis storage tank located in the 8-hr ozone control area or any ozone non-attainment area or attainment/maintenance area(Regulation 7,Part 0,Section IA,1)? Yes Continue-You have indicated th 2. Is this storagetank located at oil and gas operations that collect,store,or handle hydrocarbon liquids or produced water AND that are located at or upstream of a natural gas processing plant(Regulation 7,Part D,Section l.A.11? Yen Continue-You have indicated th 3. Is this storage tank located at a natural gas processing plant(Regulation 7,Part O,Section I,G)? No Storage Tank is not subject to Re 4, Does this storage tank contain condensate? 5. Does this storage tank exhibit"Flash"(e.g.storing non-stabilized liquids)emissions(Regulation],part 0,Section 1.6.717 Yes 6. Are uncontrolled actual emissions of this storage tankequelto orgreeterthan 2 tons per year VOC(Regulation 7,Part 0,Section 1,0.3.a(li))? Ni0.0.47 IStors otnk is ubie ir:Regr:latiun'7.Pert D.Sectio';I.C-F Part 0,Section I.C.1—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Part D,Section I.C.2—Emission Estimation Procedures Part e,Section 1.0—Emissions Control Requirements Part e,Section I.E—Monitoring Part D,Section I.F—Recordkeeping and Reporting Istcra - n -.pie..-t to ncula[io-7Secticn16 Part 0,Section I.G.2-t Emissions Control Requirements Porte,Section I.C.1.e and h—General Requirements for Air Pollution Control Equipment—Prevention of Leakage Colorado Regulation 7.Part 0,Section II 1. Is this storage tank located at atransmisslon/storage facility? No Continue-You have Indicated th 2. Is this storage tanks located at an oil and gas exploration and production operation,well production facility',natural gas compressor station'or natural gas processing plant°(Regulation 7,Part 0,Section II,C)? G5 tothe next question-You he 3. Does the storage tank have atxed roof(Regulation 7,Part 0,Section ILA20)? W/,1 'z Go to the next question 4 Are uncontrolled actual emissions oftll age tank equal to orgreat I 2 tons per year VOC(Regulation 7,part D,Section ILC.1CI? vo Source Is subject to parts of Regi Part D,Section Ike—General Provisions for Air Pollution Control Equipment and Prevention of Emissions Part 0,Section It.C.l-Emissions Control and Monitoring Provisions Part e,Section If.C.3-Recordkeeping Requirements • 5 Does the storage tank contain only"stabilized"liquid(Repletion 7 Part D,Section Il,C 2.b)? ]Source is subject to MI provsion IS,Jo jd, .._ «..., P,rt.5.<..ill Part 0,Section11.0.2C t and M -g for Storage Tanks fitted with Air Pollution Control Equipment Is the lled storage ranklocated ll production facliy,natural gas compressor s[a ton,car natural gas processing plant constructed en or after May 1,2020 or located at afaolW that was modified on or after May 1,2020,such 6 that an additionalcontrolled storage vessel is constructed to receive an anticipated increase in throughput of hydrocarbon liquids or produced water(Regulation 7,Part 0,Section ll.C4a()? + Storage Tank 3 not subject to Re Nth controlled rtorage tanklocated at a wellpod facility, t l gas compressorstaton,or natural gas processing plant constructed on or afterlanuary1,2021 or located at a facility that was modified on or after January1, 7 2021,such that an additional controlled stomp vessel is constructed to receive an ant'clpatedncrease in throughput of hydrocarbon liquids or produced water(Regulation 7,Part D Sectiont C4a.l l7 8.0 ',owe rank lc not ' Q. 40 CFR,Part 60,Subpart Kb,Standards of Performance for Volatile Organic timid Storage Vessels 1. Is the individual storage vessel capacity greater than or equal to 75 cubic meters(mil P-472 BBL](40 CFR 60.110b(a)l? Go to the next question 2. Does the storage vessel meet the following exemption in 60111b(d)(4)? Storage Tank 4 not subject NSPS a.Does the vessel has a design capacity less than or equal to 1,589.874 m5['10,000 BBL]used for petroleum'or condensate stored,processed,or treated prior to custody transfer'as defined In 60.111b? 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40 CFR,40.2)after July 23,1984(40 CFR60.110b(al]? 4. Does the tank meet the definition of"storage vessel.'in 60.111b? 5. Does the storage vessel store a"volatile organic liquid(VOL)"'as defined in 60.11lb? 6. Does the storage vessel meet any one of the following additional exemptions: a.Is the storage vessel a pressure vessel designed to operate In excess of 204.9 ItPa[-29.]psi)and without emissions to the atmosphere(60.110b(d)(2)1?;or -. b.The design capacity 6 greater than or equal to 151 m5[-950 BBL)and stores a liquid with a maximum true vapor pressure`less than 3.5 kPa(60.110b(b)l?;or C.The design capacity is greater than or equal to 75 M°T472 BBL]but less than 151m'[-950 BBL]and stores a liquid with a maximum true vapor pressures less than 15.0 kPa160.11ab(b)l? ] Does the storage tank meet either one ofthefoilowng exemptions from control requirements: a.The design p ty is greater than orequaito153m'P-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 3.5 kPa but less than 5.2 kta?,or b.The d ig ty is greater than or equal to 75 M°1-472 BBL]but less than 151 m'(-950 BBL]and stores a liquid with a maximum true vapor pressure greater than or equal to 15.0 kPa but less than 27.6 kPa? ?� :•- l not,,iect 1,405 Kb • • 40 CFR,Pert 60,Subpart 0000/0000a,Standards of Performance for Crude OIl and Natural Gas Production,Transmission and Distribution I 1. Is this storagevessel located ate facility in the onshore oil and natural gas production segment,natural gas processing segment er natural gas transmission and storage segment of the Industry? Continue-You have Indicated th 2. Was this storage vessel constructed,reconstructed,or modified(see define ions 40 CFR,60.2)between August 23,2011 and September 18,2015? :otb`,'!: Storage Tank S not subject NSPS 3. Was this storage vessel constructed,reconstructed,or modified(see definitions 40CFR,60.2)after September 18,2015? 'f00:/?ti7/Go to the next question 4. Are potential VOC emissions'from the Individual storage vessel greater than or equal to 6 tons per year? Storage Tank Is not subject NSPS 5. Does this storage vessel meet the definition of"storage vessel0 per 60.5430/60.5430a? `' 6, Is the rtoragevessel subject to and controlled in accordance with requirements for stamp vessels In 40 CFR Part 6,0 Subpart Kb or 40CFR Part 63 Subpart HH? i`."i'j [Note:If a storage vessel is previously determined to be subject to NSPS 0000/0000a due to emissions above 6 tons per year VOC on the applicability determination date,it should remain subject to NSPS 0000/00005 per 605365(e)l2]/6n.5365a(e)(2)even if potential VOC emissions drop below 6 tons per year] 40 CFR,Part63,Subpart MACE He,Oil and Gas Production Facilities 1. Is the storage tank located et en oil and natural gas production facility that meets either ofthefollowing criteria: 755 Continue-you have indicated th a.A facility that processes,upgrades or stores hydrocarbon liquids'(63.760(a)(2)I;OR b.A facility that processes,upgrades or stores natural gas prior to the point at which natural gas enters the natural gastransm'sion and storage source category or is delivered to a final end user'(63.760(a)(3))? 2. Is the tank located ate facility that A major'for HAPs? jA40.N Storage Tank is not subject MAC 3. Does the tank meet the definition of"storage vessel"'in 63.761? 4. Does the tank meet the definition of"storage vessel with the potential forflash emissions"'per 63.761? • - 5. Isthe tank subjert to control requirements under 40 CFR Part 60,Subpart Kb or Subpart 0000? Subpart A,General provisions per 063.764(a)Table 2 §63.766-Emissions Control Standards §63.773-Monitoring §63.774-Recordkeeping 063.775-Reporting RACT Review • PACT review is required if Regulation]does not apply AND It the tank is in the non-attainment area.If the tank meets both criteria,then review RACT requirements. Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the Individual facts and circumstances.This document does not change or substitute for any law,regulation, or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„ifs implementing regulations, and Air Quality Control Commission regulations,the language of the statute orregulation will control.The use of non-mandatory language such as'recommend,"'may,""should,"and'can,"is intended to • describe APCD interpretations and recommendations.Mandatory terminology such as"must"end'required"are intended to describe controlling requirements under the terms of the Clean Air Act end Air Qualify Control Commission regulations,but this document does not establish legally binding requirements in and of itself. • • • • • COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION CONTROL DIVISION FACILITY EMISSION SUMMARY Company Name PDC Energy,Inc. County AIRS ID 123 History File Edit Date 11/312020 Plant AIRS ID 9FE5 Ozone Status Non-Attainment Facility Name Wiedeman Federal 22 Sec HZ EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) AIRS PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 0.5 0.5 0.0 0.0 71.3 986.8 0.0 65.0 33.1 0.5 0.5 0.0 0.0 8.8 60.6 0.0 16.2 2.1 Previous Permitted Facility total 0.5 0.5 0.0 0.0 55.3 983.2 0.0 50.4 33.1 0.5 0.5 0.0 0.0 7.4 59.6 0.0 13.5 2.1 001 18WE0854 Twenty condensate tanks 0.2 0.2 2.0 457.1 4.2 15.6 0.2 0.2 2.0 22.9 4.2 0.8 Point updated on 11!'3l2U2U.Updated requested emissions.DC 11/3/2020. 002 GP07 Condensate Loadout _ 0.2 41.2 0.3 0.7 0.2 10.0 0.3 0.0 No Change. 003 GP02 51 RICE GM Vortec 5.7L,4SRB,87 HP(site 0.1 0.1 11.8 0.6 9.3 0.1 0.1 0A 0.9 0.6 1.7 0A No Change rated),SN:10CHMM408180020__ 004 GP02 SI RICE GM Vortec 5.7L,4SRB,87 HP(site 0.1 0A 11.8 0.6 9.3 0.1 0A 0A 0.9 0.6 1.7 0A No Change rated),SN:10CHMM5D3060104 005 GP02 51 RICE GM Vortec 5.7L,4SRB,87 HP(site 0A 0A 11.8 0.6 9.3 0.1 0.1 OA 0.9 0.6 1.7 0A No Change rated),SN:10CHMM503090026 SI RICE Red Rtver GM 9.OL,4SRB,136 HP(site 006 GP02.CN 0.0 ':0:0` Cancellation reoeiVed on 06/19/2019. rated),-Stq:;306657 �". 007 GP02 RICE 143 Hp 0A 0A 16.0 3.6 14.6 0A 0.1 0A 1.4 1.0 2.7 0.1 No Change XA External Combustion Device 0.3 0.3 3.6 0A _ 3.0 0.3 0.3 3.6 0.1 3.0 Insignificant Source XA Fugitives 0.2 0.2 Insignificant Source XA Produced Water Tanks 0.0 0.0 Insignificant Source VOC: Syn Minor(NANSR and OP) NOx:Syn Minor(NANSR and OP) FACILITY TOTAL 0.7 0.7 0.0 0.0 57.2 503.8 0.2 50.1 16.7 0.7 0.7 0.0 0.0 9.9 35.8 0.2 15.4 1.3 CO: True Minor(P50 and OP) RAPS: Syn Minor n-Hexane HH:Area source ZZZZ: Area source - Permitted Facility Total 0.4 0.4 0.0 0.0 53.6 503.7 0.0 47.1 16.7 0.4 0.4 0.0 0.0 6.3 35.7 0.0 12.4 1.3 Excludes units exempt from permits/APENs Pubcom required because source is attempting to obtain a federally enforceable limit on the (A)Change in Permitted Emissions -0A -0A 0.0 0.0 -1.1 -23.9 0.0 -1.2 -0.8 potential to emit in order to avoid other requirements.Modeling not required based on change in emissions. Total VOC Facility Emissions(point and fugitive) 36.0 Facility is eligible for GP02 because CO<90 tpy& VOC/Nox<45 tpy. (A)Change in Total Permitted VOC emissions(point and fugitive) -23.9 Project emissions greater than 25 tpy Note 1 Page 8 of 9 _ Printed 12/1/2020 COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT AIR POLLUTION DIVISION FACILITY EMISSION SUMMARY-HAPs Company Name PDC Energy,Inc. County AIRS ID 123 Plant AIRS ID 9FE5 Facility Name Wiedeman Federal 22 Sec HZ Emissions-uncontrolled(lbs per year) POINTI PERMIT I Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL(tpy) Previous FACILITY TOTAL 0.3 0.0 0.0 2.8 4.0 0.1 1.3 24.5 0.0 0.0 33.1 001 18WE0854 Twenty condensate tanks 2656.5 3904.0 79.4 1231.1 23290.4 40:1 15.6 002 GP07 Condensate Loadout 145.1 1260.0 0.7 SI RICE GM Vortec 5.7L,4SRB,87 003 GP02 HP(site rated),SN: 133.2 18.1 17.1 10.3 19.9 0.1 10CH MM408 180020 SI RICE GM Vortec 5.7L,4SRB,87 004 GP02 HP(site rated),SN: 133.2 18.1 17.1 (0.3 19.9 0.1 10CHMM503060104 SI RICE GM Vortec 5.7L,4SRB,87 005 GP02 HP(site rated),SN: 133.2 18.1 17.1 10.3 19.9 0.1 10CHMM503090026 006 GP02.CN SI RIGE:Red,River GM 9,OL,4SRB, 0.0 136 HP(site rated),SNN 306657 007 GP02 RICE 143 Hp 208.2 28.3 26.7 16.0 0.1 0.0 XA External Combustion Device 0.0 XA Fugitives 9,'I 9.1 8.8 8,9 10.4 0.0 XA Produced Water Tanks 2.6 3.1 0.1 0.6 0.4 0.0 0.0 TOTAL(tpy) 0.3 0.0 0.0 1.4 2.0 0.0 0.6 12.3 0.0 0.0 16.8 Emissions with controls(lbs per year) POINTI PERMIT I Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP TOTAL(tpy) Previous FACILITY TOTAL 0.3 0.0 0.0 0.2 0.2 0.0 0.1 1.2 0.0 0.0 , 2.1 001 18WE0854 Twenty condensate tanks 132.8 195.2 4.0 61.6 1164.5 2.0 0.8 002 GP07 Condensate Loadout 7,3 63.0 0.0 SI RICE GM Vortec 5.7L,4SRB,87 003 GP02 HP(site rated),SN: 133.2 18.1 17.1 10.3 19.9 0.1 10CHMM408180020 SI RICE GM Vortec 5.7L,4SRB,87 004 GP02 HP(site rated),SN: 133,2 18,1 17.1 10.3 19.9 0.1 10CHMM503060104 SI RICE GM Vortec 5.7L,4SRB,87 005 GP02 HP(site rated),SN: 133.2 18.1 17.1 10.3 19.9 0.1 10CH MM503090026 006 G,P02.CN S(,RICE Red River GM 9.0L,4SRB, 0 0 136 HPz(site rated),SN;306657 007 . G;;,,. ., .. ... P02 RICE 143 Hp Y08.2 28.3 26.7 18.0 0.1 0.0 XA External Combustion Device 0.0 XA Fugitives 9,1 9.1 8,3 8.9 10.4 0.0 XA Produced Water Tanks 2,6 3.1 0.1 0.(1 0.4 0.0 0.0 TOTAL(tpy) 0.3 0.0 0.0 0.1 0.1 0.0 0.0 0.6 0.0 0.0 1.3 9 18WE0854.CP2 E0854.CP2 12/1/2020 ij. f• ✓G r' Condensate Storage Tank(s) APENto �, r M �- ji Form APCD-205 'a J; i'i'' CDPHE Air Pollutant Emission Notice (APEN)and • n 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: 18WE0854 AIRS ID Number: 123 / 9FE5/001 [Leave blank unless APCD has already assigned a permit If and AIRS ID] Section 1 -Administrative Information Company Name': PDC Energy, Inc. Site Name: wedeman Federal 22 Sec HZ Site Location Site Location: NWSW Sec 22 T4N 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 i 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. 1/(N 1g COLORADO Form APCD 205 Condensate Storage Tank(s)APEN Revision 12/2019 1 I eI a."�d Permit Number: 18WE0854 AIRS ID Number: 123 /9FE5/001 [Leave blank.unless APCD has already assigned a permit#and AIRS ID] Section 2 - Requested Action ❑ NEW permit OR newly-reported emission source ❑ 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- O MODIFICATION to existing permit(check each box below that applies) El Change in equipment ❑ Change company name3 r❑ Change permit limit ❑ Transfer of ownership' O Other(describe below) -OR • APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PER/AIT 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 Et Notes: Requesting new throughput limit and emissions limits for Construction Permit 18WE0854; 2019 Actual throughput; Emissions calculated using previously approved site-specific emission factors. 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership,a completed Transfer of Ownership Certification Form(Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Condensate Storage Tanks Company equipment Identification No. (optional): TK-1 For existing sources, operation began on: 5/4/2018 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: 0 Exploration Et Production(E&P)site O Midstream or Downstream (non E&P)site Will this equipment be operated in any NAAQS nonattainment area? ID Yes O No Are Flash Emissions anticipated from these storage tanks? ❑✓ Yes O No Is the actual annual average hydrocarbon liquid throughput≥500 bb(/day? ❑ Yes El No If"yes", identify the stock tank gas-to-oil ratio: m3/liter Are these storage tanks subject to Colorado Oil and Gas Conservation Commission (COGCC) Q 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 ❑ No emissions a 6 ton/yr(per storage tank)? COLORADO Form APCD 205 Condensate Storage Tank(s)APEN Revision 12/2019 2 I I,Daproorent.',Public �„ Permit Number: 18WE0854 AIRS ID Number: 123 /9FE5/001 [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 (bbl/year) (bbl/year) Condensate Throughput: 170,247 170,247 From what year is the actual annual amount? 2019 Average API gravity of sales oil: 61.9 degrees RVP of sales oil: 10.3 Tank design: 0 Fixed roof O Internal floating roof O External floating roof Storage #of Liquid Manifold Storage Total Volume of Installation Date of Most Date of First Tank ID Vessels in Storage Tank Storage Tank Recent Storage Vessel in Production (bbl) Storage Tank(month/year) (month/year) TK-1 10 5,380 11/2017 5/2018 Wells Serviced by this Storage Tank or Tank Battery'(MP Sites Only) API Number Name of Well Newly Reported Well 05 - 123 - 43391 Wiedeman Federal 22G-232 ❑ 05 - 123 - 43392 Wiedeman Federal 22G-302 ❑ 05 - 123 - 43390 Wiedeman Federal 22H-212 O 05 - 123 - 43394 Wiedeman Federal 22H-232 0 05 - 123 - 43389 Wiedeman Federal 22H-302 ❑ 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 wells that are serviced by the equipment reported on this APEN form. Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.295901/-104.772243 El 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) (ft/sec) Indicate the direction of the stack outlet: (check one) O Upward O Downward ❑Upward with obstructing raincap ❑Horizontal O Other(describe): Indicate the stack opening and size: (check one) O Circular Interior stack diameter(inches): o Square/rectangle Interior stack width(inches): Interior stack depth(inches): ❑Other(describe): COLORADO Form APCD 205 Condensate Storage Tank(s)APEN Revision 12/2019 3 OI MOM lo H�� Permit Number: 18WE0854 - AIRS ID Number: 123 /9FE5/001 [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 and HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model: 10 x Cimarron 48",1 x Cimarron 60" ❑ Combustion Requested Control Efficiency: 95 Device: Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2,571 Btu/scf Constant Pilot Light: El Yes ❑ No Pilot Burner Rating: 0.195 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&P Sites Only) What is the pressure of the final separator vessel prior to discharge to the storage tank(s)? 47.1 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator COLORADO Form APCD 205 Condensate Storage Tank(s)APEN Revision 12/2019 4 I 4O1„° a„ , Permit Number: 18WE0854 AIRS ID Number: 123 /9FE5/001 [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 form]. Is any emission control equipment or practice used to reduce emissions? 0 Yes O No If yes,describe the control equipment AND state the collection and control efficiencies(report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) VOC Enclosed Combustors 100% 95% NOx CO HAPS Enclosed Combustors 100% 95% Other: From what year is the following reported actual annual emissions data? 2019 Use the following table to report the criteria pollutant emissions from source: Emission Factor? Actual Annual Emissions Requested Annual Permit Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissions8 Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) ' (tons/year) VOC 5.3699 Ib/bbl ProMax 457.11 22.56 457.11 22.86 NO. 0.1380 Ib/MMBtu TCEQ NIA 2.04 N/A 2.04 CO 0.2755 Ib/MMBtu TCEQ NIA 4.22 N/A 4.22 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 0 Yes ❑No pollutants(e.g. HAP-hazardous air pollutant)equal to or greater than 250 lbs/year? If yes, use the following table to report the non-criteria pollutant(HAP)emissions from source: Chemical Emission Factor? Actual Annual Emissions Chemical Name Abstract Source Uncontrolled Controlled Uncontrolled Service(CAS) Basis Units (AP-42, Emissions Emissfons8 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.0156 lb/bbl ProMax 2,656.52 132.83 Toluene 108883 0.0229 Ib/bbl ProMax 3,904.01 195.20 Ethylbenzene 100414 4.87E-04 Ib/bbl ProMax 79.44(DM) 3.97(DM) Xylene 1330207 0.0072 lb/bbl ProMax 1,231.11 61.56 n-Hexane 110543 0.1368 Ib/bbl ProMax 23,290.37 1,164.52 2,2,4-Trimethylpentane 540841 2.35E-04 lb/bbl ProMax 40.09(DM) 2.00(DM) 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 1.a . Permit Number: 18WE0854 AIRS ID Number: 123 /9FE5/001 [Leave blank unless APCD has already assigned a permit a and AIRS IDI Section 10- 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. Si ure of Legally Authorized Person (not a vendor or consultant) Date J ck Starr Senior Air Quality Representative Name(print) Title Check the appropriate box to request a copy of the: ❑� Draft permit prior to issuance ✓l 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 Air Pollution Control Division OR APCD-SS-B1 (303)692-3148 4300 Cherry Creek Drive South Denver,CO 80246-1530 APCD Main Phone Number (303)692-3150 Make check payable to: Colorado Department of Public Health and Environment COLORADO Form APCD 205 Condensate Storage Tank(s)APEN Revision 12/2019 6 I ®Ilandward E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: PDC Energy,Inc. Source Name: Wiedeman Federal 22 Sec HZ Emissions Source AIRS ID2: 123/9FE5/001 Wells Services by this Storage Tank or Tank Battery(E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-43396 Wiedeman Federal 22H-312 ❑ 05-123-43393 Wiedeman Federal 22H-332 ❑ 05-123-43397 Wiedeman Federal 22H-402 ❑ 05-123-43395 Wiedeman Federal 221-212 ❑ 05-123-43398 Wiedeman Federal 221-302 ❑ - - ❑ 0 0 - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ - - ❑ Footnotes: ' Attach this addendum to associated APEN form when needed to report additional wells. z If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter N/A Form APCD-212 TK-1 Addendum Hello