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Home My WebLink About20202659.tiff �XFx�J COLORADO Department of Public Health&Environment RECEIVED AUG 0 4 2020 WELD COUNTY COMMISSIONERS Weld County - Clerk to the Board - 1150OSt PO Box 758 Greeley, CO 80632 July 29, 2020 Dear Sir or Madam: On July 30, 2020, the Air Pollution Control Division will begin a 30-day public notice period for PDC Energy, Inc. - Thistle Down 31 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 o1c6 \ 4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.cotorado.gov/cdphe I ,tom ° '6 Jared Potts,Governor I Jill Hunsaker Ryan,MPH, Executive Director ;*' PUbI :C Rev ; ec.J cc:Pi^(TP), NI_(DS), p 3((M/ta./G+1/cK), 2020-2659 oq/n2/20 o�Csh•) ois/21'/20 � : Air Pollution Control Division • �.:Y�li► Notice of a Proposed Project or Activity Warranting Public CDPHE' Comment Website Title: PDC Energy, Inc. - Thistle Down 31 Sec HZ - Weld County Notice Period Begins: July 30, 2020 Notice is hereby given that an application for a proposed project or activity has been submitted to the Colorado Air Pollution Control Division for the following source of air pollution: Applicant: PDC Energy, Inc. Facility: Thistle Down 31 Sec HZ Well Production Facility NESW of Section 31, Township 5N, Range 64W Weld County The proposed project or activity is as follows: PDC Energy, Inc. is requesting permit coverage for eleven (11) 538 barrel fixed roof condensate storage vessels and one (1) surge vessel at a new synthetic minor oil and gas well production facility located in the ozone non-attainment area. The Division has determined that this permitting action is subject to public comment per Colorado Regulation No. 3, Part B, Section III.C due to the following reason(s): • permitted emissions exceed public notice threshold values in Regulation No. 3, Part B, Section III.C.1.a (25 tpy in a non-attainment area and/or 50 tpy in an attainment area) • the source is requesting a federally enforceable limit on the potential to emit in order to avoid other requirements The Division has made a preliminary determination of approval of the application. A copy of the application, the Division's analysis, and a draft of Construction Permit 19WE1027 it 20WE0603 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: Harrison Slaughter, P.E. Colorado Department of Public Health and Environment 4300 Cherry Creek Drive South, APCD-SS-B1 COLORADO 1 a 4,41 40 Department of Public co""c Health b Environment Denver, Colorado 80246-1530 COLORADO Department of Public 2 I ow c Health 6 Environment ,„, - COLORADO Air Pollution Control Division CDPH Ck rtrfenl O PublV.t fealUi Et Ermrt.vrrlry Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 19WE1027 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: Thistle Down 31 Sec HZ Plant AIRS ID: 123/A0A5 Physical Location: NESW SEC 31 T5N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Facility AIRS Emissions Control Equipment Point Equipment Description Description ID Eleven (11) 538 barrel fixed roof Enclosed TK-1 001 condensate storage vessels connected via Combustor(s) liquid manifold. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to the specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self-certify compliance as required by this permit may be obtained online at www.colorado.gov/cdphe/air- permit-self-certification. (Regulation Number 3, Part B, Section III.G.2.) 2. This permit must expire if the owner or operator of the source for which this permit was issued: (i) does not commence construction/modification or operation of this source within 18 months after either, the date of issuance of this construction permit or the date on which such construction or activity was scheduled to commence as set forth in the permit application associated with this permit; (ii) discontinues construction for a period of eighteen months or Page 1 of 10 COLORADO je , Air Pollution Control Division GDP" DEY. lrnc₹t Pubb_tiealttl&_r iroi=Jnen1 Dedicated to protecting and improving the health and environment of the people of Colorado more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) I.F.4.) 3. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) ) Annual Limits: Facility AIRS Tons per Year Emission Equipment ID Point PM2.5 NO, VOC CO Type TK-1 001 --- 1.2 13.5 2.5 Point Note: See "Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Facility AIRS Pollutants Equipment Point Control Device Controlled ID TK-1 001 Enclosed Combustor(s) VOC and HAP PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made Page 2 of 10 ,, COLORADO Air Pollution Control Division DP E Ck arlt w.,E O Pub Ffea i grisourirne5; Dedicated to protecting and improving the health and environment of the people of Colorado available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) Process Limits Facility AIRS Equipment Point Process Process Parameter Annual Limit ID Condensate throughput routed directly from the 01 three-phase 91,583 barrels TK-1 001 separators to the condensate storage vessels 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 9. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 10. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) 11. This source is subject to Regulation Number 7, Part D, Section I. The operator must comply with all applicable requirements of Section I and, specifically, must: • Comply with the recordkeeping, monitoring, reporting and emission control requirements for storage tanks; and • Ensure that the combustion device controlling emissions from this storage tank be enclosed, have no visible emissions, and be designed so that an observer can, by means of visual observation from the outside of the enclosed combustion device, or by other means approved by the Division, determine whether it is operating properly. (Regulation Number 7, Part D, Section I.C.) (State only enforceable) 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient Page 3 of 10 a , COLORADO of Division C PHE DeoaftRte!il %N>:hfeant 6 u5virti tu'rtt.A Dedicated to protecting and improving the health and environment of the people of Colorado means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. The storage tank covered by this permit is subject to the emission control requirements in Regulation Number 7, Part D, Section II.C.1. The owner or operator must install and operate air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons except where the combustion device has been authorized by permit prior to March 1, 2020. The source must follow the inspection requirements of Regulation Number 7, Part D, Section II.C.1.d. and maintain records of the inspections for a period of two years, made available to the Division upon request. This control requirement must be met within 90 days of the date that the storage tank commences operation. 14. The storage tanks covered by this permit are subject to the venting and Storage Tank Emission Management System ("STEM") requirements of Regulation Number 7, Part D, Section II.C.2. 15. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING ft MAINTENANCE REQUIREMENTS 16. Upon startup of this point, 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 17. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 18. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS 19. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: Page 4 of 10 Air Poll' COLORADO Control Division CDPHE ot, =1 rlr_}1 o Put&fiealrti t1 vtrExIne e 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 (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NOx per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 20. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Emissions - tons per year Facility AIRS Equipment Current Equipment Point Description Pollutant p ID Threshold Permit Limit Condensate TK-1 001 Storage VOC 50 35.5 Vessels Hydrocarbon NOx 50 11.4 LOAD-1 002 Loadout Page 5 of 10 •. . COLORADO Air Pollution Control Division 6PHE Depivirr iegi ud Pubic iteaii)i h ulytmxt en1 Dedicated to protecting and improving the health and environment of the people of Colorado ENG-1 003 SI RICE ENG-2 004 SI RICE ENG-3 005 SI RICE ENG-4 006 SI RICE Surge 008 Separator Vessel Insignificant ___ __ Sources Note: The insignificant sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 21. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 22. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7- 114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 23. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 24. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 25. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a Page 6 of 10 . -_, COLORADO Air Pollution Control Division pPN I Devaftqw.q1 oe Pubic Fierilrti£a trmon.sut)en? Dedicated to protecting and improving the health and environment of the people of Colorado permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 26. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 27. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issuance 1 This Issuance Issued to PDC Energy, Inc. Permit for eleven (11) condensate storage vessels at a new synthetic minor oil and gas well production facility. Page 7 of 10 ' COLORADO Air Pollution Control Division 'i rtr lent O aub1r_Health&Ervercelheni Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See: https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the source(s) operate at the permitted limitations. AIRS Uncontrolled Controlled Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 1,158 58 Toluene 108883 1,463 74 Ethylbenzene 100414 36 2 001 Xylenes 1330207 519 26 n-Hexane 110543 11,846 593 2,2,4- 540841 18 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 001: Process 01: Condensate throughput routed directly from the three-phase separators to the condensate storage vessels Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 2.42x10-2 2.42x10-2 TNRCC Page 8 of 10 I COLORADO i:. Air Pollution Control Division Depairiwnt ,bb treaYtt b&. r ,ter Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 4.82x10-2 4.82x10-2 TNRCC VOC 5.885 2.942x10-1 ProMax 71432 Benzene 1.264x102 6.318x10-4 ProMax 108883 Toluene 1.597x10-2 7.984x10-4 ProMax 1330207 Xylene 5.666x10-3 2.833x1O4 ProMax 110543 n-Hexane 1.293x10-1 6.467x10-3 ProMax Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the outlet of the low pressure separator for the Thistle Down 31G-332 well on 10/17/2019. The sample pressure and temperature are 24.9 psig and 103°F respectively. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively) in the table above were converted to units of lb/bbl using a gas molecular weight of 47.1122 lb/lbmote, a standard molar volume of 379.41 scf/lb-mole, a VOC mole % of 72.01629147% and a heat content of 2,660.9186 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total condensate throughput. Process 02: Combustion of pilot light gas Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/MMSCF lb/MMSCF NOx 77.25 77.25 AP-42 Chapter 13.5 CO 352.16 352.16 AP-42 Chapter 13.5 VOC 6.13 6.13 AP-42 Chapter 1.4 Table 1.4-2 Note: The NOx and CO emission factors listed in the table above were obtained by multiplying the AP-42 Chapter 13.5 NOx and CO emission factors (0.068 lb/MMBtu and 0.31 lb/MMBtu respectively) by a heat value of 1,136 Btu/scf. The VOC emission factor in the table above was obtained by multiplying the AP-42 Chapter 1.4 emission factor by a ratio of 1,136 Btu/scf to 1,020 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total fuel flow of the pilot light gas. Pilot light gas fuel flow is based on a constant rate of 15.6 scf/hr. There are a total of eleven 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. Total actual emissions are obtained from the sum of emissions resulting from the storage vessels and combustion of waste gas from the storage vessels (process 01) and the combustion of pilot light gas (process 02) 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each Page 9 of 10 ' COLORADO - Air Pollution Control Division eeNr r1871£'.it` Pubic tfeaD f1 Ltl°t dr„i`dtle-V, Dedicated to protecting and improving the health and environment of the people of Colorado emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This permit fulfills the requirement to hold a valid permit reflecting the storage tank and associated control device per the Colorado Oil and Gas Conservation Commission rule 805b(2)(A) when applicable. 8) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO, and NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC and NOx MACT HH Area Source Requirements Not Applicable Major Source Requirements: Not Applicable 9) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the website listed below: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 a . ( COLORADO Air Pollution Control Division CDPNE ! ot- r;ro,,,:&"Pub Hedlrh E itl,er'6rvrlt-'d Dedicated to protecting and improving the health and environment of the people of Colorado CONSTRUCTION PERMIT Permit number: 20WE0603 Issuance: 1 Date issued: Issued to: PDC Energy, Inc. Facility Name: Thistle Down 31 Sec HZ Plant AIRS ID: 123/A0A5 Physical Location: NESW SEC 31 T5N R64W County: Weld County Description: Well Production Facility Equipment or activity subject to this permit: Equipment AIRS Emissions Control Equipment Description ID Point Description Natural gas flaring from one (1) surge Enclosed Surge Vessel 008 vessel during vapor recovery unit (VRU) Combustor(s) downtime. This permit is granted subject to all rules and regulations of the Colorado Air Quality Control Commission and the Colorado Air Pollution Prevention and Control Act (C.R.S. 25-7-101 et seq), to this specific general terms and conditions included in this document and the following specific terms and conditions. REQUIREMENTS TO SELF-CERTIFY FOR FINAL AUTHORIZATION 1. Within one hundred and eighty days (180) of the latter of commencement of operation or issuance of this permit, compliance with the conditions contained in this permit must be demonstrated to the Division. It is the owner or operator's responsibility to self-certify compliance with the conditions. Failure to demonstrate compliance within 180 days may result in revocation of the permit. A self certification form and guidance on how to self- certify compliance as required by this permit may be obtained online at www.colorado.gov/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 Page 1 of 10 DO Air Pollution Control ivision► C©PHE aL:lot-Nell o"Put e Health Er tnmruirnE:,1 Dedicated to protecting and improving the health and environment of the people of Colorado months or more; (iii) does not complete construction within a reasonable time of the estimated completion date. The Division may grant extensions of the deadline. (Regulation Number 3, Part B, Section III.F.4.) 3. The operator must complete all initial compliance testing and sampling as required in this permit and submit the results to the Division as part of the self-certification process. (Regulation Number 3, Part B, Section III.E.) 4. The operator must retain the permit final authorization letter issued by the Division, after completion of self-certification, with the most current construction permit. This construction permit alone does not provide final authority for the operation of this source. ' EMISSION LIMITATIONS AND RECORDS 5. Emissions of air pollutants must not exceed the following limitations. (Regulation Number 3, Part B, Section II.A.4.) Annual Limits: AIRS Tons per Year Emission Equipment ID Point PM2.5 NO. VOC CO Type Surge Vessel 008 --- 0.5 6.8 1.0 Point Note: See"Notes to Permit Holder"for information on emission factors and methods used to calculate limits. Compliance with the annual limits, for criteria pollutants, must be determined on a rolling twelve (12) month total. By the end of each month a new twelve month total is calculated based on the previous twelve months' data. The permit holder must calculate actual emissions each month and keep a compliance record on site or at a local field office with site responsibility for Division review. 6. The owner or operator must use the emission calculation methods and emission factors found in the Notes to Permit Holder to calculate emissions and show compliance with the limits contained in this permit. The owner or operator must submit an Air Pollutant Emission Notice (APEN) and receive a modified permit prior to the use of any other method of calculating emissions. 7. The emission points in the table below must be operated and maintained with the emissions control equipment as listed in order to reduce emissions to less than or equal to the limits established in this permit. (Regulation Number 3, Part B, Section III.E.) Equipment AIRS Control Device Pollutants ID Point Controlled Emissions from the surge vessel are routed Surge Vessel 008 to Enclosed Combustor(s) during Vapor VOC and HAP Recovery Unit (VRU) downtime Page 2 of 10 #•- . COLORADO Air Pollution Control Division CDPH C* timer.o Pubb_'tfie Je b zr wtrtxubt Dedicated to protecting and improving the health and environment of the people of Colorado PROCESS LIMITATIONS AND RECORDS 8. This source must be limited to the following maximum processing rates as listed below. Monthly records of the actual processing rates must be maintained by the owner or operator and made available to the Division for inspection upon request. (Regulation Number 3, Part B, Section II.A.4.) ) Process Limits Equipment ID AIRS Process Parameter Annual Limit Point Surge vessel hydrocarbon Surge Vessel 008 liquid throughput during 45,792 barrels vapor recovery unit (VRU) downtime. The owner or operator must monitor monthly process rates based on the calendar month. Compliance with the annual throughput limits must be determined on a rolling twelve (12) month total. By the end of each month a new twelve-month total is calculated based on the previous twelve months' data. The permit holder must calculate throughput each month and keep a compliance record on site or at a local field office with site responsibility, for Division review. 9. The owner or operator shall monitor and record surge vessel vapor recovery unit (VRU) downtime on a daily basis. Surge vessel VRU downtime shall be defined as times when waste gas vented from the surge vessel is routed through the storage vessels to be controlled by the enclosed combustor(s) rather than the VRU. The total hours of VRU downtime, total hydrocarbon liquid throughput routed through the surge vessel during VRU downtime, and total hydrocarbon liquid throughput through the surge vessel shall be recorded on a monthly basis. The owner or operator must use monthly VRU downtime records, monthly surge vessel hydrocarbon liquid throughput records and the calculation methods established in the Notes to Permit Holder to demonstrate compliance with the process and emission limits specified in this permit. STATE AND FEDERAL REGULATORY REQUIREMENTS 10. The permit number and ten digit AIRS ID number assigned by the Division (e.g. 123/4567/001) must be marked on the subject equipment for ease of identification. (Regulation Number 3, Part B, Section III.E.) (State only enforceable) 11. This source is subject to the odor requirements of Regulation Number 2. (State only enforceable) • 12. The combustion device covered by this permit is subject to Regulation Number 7, Part D, Section II.B.2. General Provisions (State only enforceable). If a flare or other combustion device Page 3 of 10 „, _ ,-,A,' ,a ”" ' 1 Mr Pollution Control Division CDpHH Dma!I nrna cY Pubk Hea,.:h b Erivul,ornen1 Dedicated to protecting and improving the health and environment of the people of Colorado is used to control emissions of volatile organic compounds to comply with Section II, it must be enclosed; have no visible emissions during normal operations, as defined under Regulation Number 7, Part D, Section II.A.23; and be designed so that an observer can, by means of visual observation from the outside of the enclosed flare or combustion device, or by other convenient means approved by the Division, determine whether it is operating properly. This flare must be equipped with an operational auto-igniter according to the schedule in Regulation Number 7, Part D, Section II.B.2.d. 13. The separator covered by this permit is subject to Regulation 7, Part D, Section II.F. On or after August 1, 2014, gas coming off a separator, produced during normal operation from any newly constructed, hydraulically fractured, or recompleted oil and gas well, must either be routed to a gas gathering line or controlled from the commencement of operation by air pollution control equipment that achieves an average hydrocarbon control efficiency of 95%. If a combustion device is used, it must have a design destruction efficiency of at least 98% for hydrocarbons. 14. On or before June 30th, 2021 (and on June 30th each year thereafter), the owner or operator of oil and natural gas operations and equipment at or upstream of a natural gas processing plant in Colorado must submit a single annual report that includes actual emissions and specified information in the Division-approved report format. The information included in the annual report must be in accordance with the general reporting requirements of Regulation Number 7, Part D, Section V.B. Beginning July 1, 2020, and each calendar year thereafter, owners or operators must maintain the information according to Regulation Number 7, Part D, Section V.C. for inclusion in the annual report. (Regulation Number 7, Part D, Section V) OPERATING Et MAINTENANCE REQUIREMENTS 15. Upon startup of this point, 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 O&M plan are subject to Division approval prior to implementation. (Regulation Number 3, Part B, Section III.G.7.) COMPLIANCE TESTING AND SAMPLING Initial Testing Requirements 16. This source is not required to conduct initial testing, unless otherwise directed by the Division or other state or federal requirement. Periodic Testing Requirements 17. This source is not required to conduct periodic testing, unless otherwise directed by the Division or other state or federal requirement. ADDITIONAL REQUIREMENTS Page 4 of 10 , COLORADO Mr Pollution Control Division I DKaor let nt testtth Er=rrvresrir a Dedicated to protecting and improving the health and environment of the people of Colorado 18. A revised Air Pollutant Emission Notice (APEN) must be filed: (Regulation Number 3, Part A, Section II.C.) • Annually by April 30th whenever a significant increase in emissions occurs as follows: For any criteria pollutant: For sources emitting less than 100 tons per year, a change in actual emissions of five (5) tons per year or more, above the level reported on the last APEN; or For volatile organic compounds (VOC) and nitrogen oxides sources (NOx) in ozone nonattainment areas emitting less than 100 tons of VOC or NO, per year, a change in annual actual emissions of one (1) ton per year or more or five percent, whichever is greater, above the level reported on the last APEN; or For sources emitting 100 tons per year or more, a change in actual emissions of five percent or 50 tons per year or more, whichever is less, above the level reported on the last APEN submitted; or For any non-criteria reportable pollutant: If the emissions increase by 50% or five (5) tons per year, whichever is less, above the level reported on the last APEN submitted to the Division. • Whenever there is a change in the owner or operator of any facility, process, or activity; or • Whenever new control equipment is installed, or whenever a different type of control equipment replaces an existing type of control equipment; or • Whenever a permit limitation must be modified; or • No later than 30 days before the existing APEN expires. 19. The requirements of Colorado Regulation Number 3, Part D must apply at such time that any stationary source or modification becomes a major stationary source or major modification solely by virtue of a relaxation in any enforceable limitation that was established after August 7, 1980, on the capacity of the source or modification to otherwise emit a pollutant such as a restriction on hours of operation (Regulation Number 3, Part D, VI.B.4/V.A.7.B). With respect to this Condition, Part D requirements may apply to future modifications if emission limits are modified to equal or exceed the following threshold levels: Pollutant Emissions - tons per year Page 5 of 10 a _ 4 COLORADO Air Pollution Control Division CDPHE (De 'DT*,tl o'Pub(-!{eadrti C LnvZruvine.`9 Dedicated to protecting and improving the health and environment of the people of Colorado Facility AIRS Equipment Current Equipment Threshold Permit Point Description ID Limit Condensate TK-1 001 Storage Vessels LOAD-1 002 Hydrocarbon Loadout ENG-1 003 SI RICE ENG-2 004 SI RICE VOC 50 35.5 ENG-3 005 SI RICE NOx 50 11.4 ENG-4 006 SI RICE Surge 008 Separator Vessel ___ ___ Insignificant Sources Note: The insignificant sources do not have permit limits. However, the PTE of these sources (excluding fugitives) is still considered in the project increase when evaluating PSD and NANSR. GENERAL TERMS AND CONDITIONS 20. This permit and any attachments must be retained and made available for inspection upon request. The permit may be reissued to a new owner by the APCD as provided in AQCC Regulation Number 3, Part B, Section II.B. upon a request for transfer of ownership and the submittal of a revised APEN and the required fee. 21. If this permit specifically states that final authorization has been granted, then the remainder of this condition is not applicable. Otherwise, the issuance of this construction permit does not provide "final" authority for this activity or operation of this source. Final authorization of the permit must be secured from the APCD in writing in accordance with the provisions of 25-7-114.5(12)(a) C.R.S. and AQCC Regulation Number 3, Part B, Section III.G. Final authorization cannot be granted until the operation or activity commences and has been verified by the APCD as conforming in all respects with the conditions of the permit. Once self-certification of all points has been reviewed and approved by the Division, it will provide written documentation of such final authorization. Details for obtaining final authorization to operate are located in the Requirements to Self-Certify for Final Authorization section of this permit. 22. This permit is issued in reliance upon the accuracy and completeness of information supplied by the owner or operator and is conditioned upon conduct of the activity, or construction, installation and operation of the source, in accordance with this information and with Page 6 of 10 COLORADO Air Pollution Control Division DM I Dedicated to protecting and improving the health and environment of the people of Colorado representations made by the owner or operator or owner or operator's agents. It is valid only for the equipment and operations or activity specifically identified on the permit. 23. Unless specifically stated otherwise, the general and specific conditions contained in this permit have been determined by the APCD to be necessary to assure compliance with the provisions of Section 25-7-114.5(7)(a), C.R.S. 24. Each and every condition of this permit is a material part hereof and is not severable. Any challenge to or appeal of a condition hereof must constitute a rejection of the entire permit and upon such occurrence, this permit must be deemed denied ab initio. This permit may be revoked at any time prior to self-certification and final authorization by the Air Pollution Control Division (APCD) on grounds set forth in the Colorado Air Quality Control Act and regulations of the Air Quality Control Commission (AQCC), including failure to meet any express term or condition of the permit. If the Division denies a permit, conditions imposed upon a permit are contested by the owner or operator, or the Division revokes a permit, the owner or operator of a source may request a hearing before the AQCC for review of the Division's action. 25. Section 25-7-114.7(2)(a), C.R.S. requires that all sources required to file an Air Pollution Emission Notice (APEN) must pay an annual fee to cover the costs of inspections and administration. If a source or activity is to be discontinued, the owner must notify the Division in writing requesting a cancellation of the permit. Upon notification, annual fee billing will terminate. 26. Violation of the terms of a permit or of the provisions of the Colorado Air Pollution Prevention and Control Act or the regulations of the AQCC may result in administrative, civil or criminal enforcement actions under Sections 25-7-115 (enforcement), -121 (injunctions), -122 (civil penalties), -122.1 (criminal penalties), C.R.S. By: Harrison Slaughter, P.E. Permit Engineer Permit History Issuance Date Description Issued to PDC Energy, Inc. Issuance 1 This Issuance Permit for one (1) surge vessel at a new synthetic minor well production facility. Page 7 of 10 COLORADO Mr Pollution Control Division DPH1 ,Terre*rt ?ub€r:Health&'Envirce xneni. Dedicated to protecting and improving the health and environment of the people of Colorado Notes to Permit Holder at the time of this permit issuance: 1) The permit holder is required to pay fees for the processing time for this permit. An invoice for these fees will be issued after the permit is issued. The permit holder must pay the invoice within 30 days of receipt of the invoice. Failure to pay the invoice will result in revocation of this permit. (Regulation Number 3, Part A, Section VI.B.) 2) The production or raw material processing limits and emission limits contained in this permit are based on the consumption rates requested in the permit application. These limits may be revised upon request of the owner or operator providing there is no exceedance of any specific emission control regulation or any ambient air quality standard. A revised air pollution emission notice (APEN) and complete application form must be submitted with a request for a permit revision. 3) This source is subject to the Common Provisions Regulation Part II, Subpart E, Affirmative Defense Provision for Excess Emissions During Malfunctions. The owner or operator must notify the Division of any malfunction condition which causes a violation of any emission limit or limits stated in this permit as soon as possible, but no later than noon of the next working day, followed by written notice to the Division addressing all of the criteria set forth in Part II.E.1 of the Common Provisions Regulation. See:`https://www.colorado.gov/pacific/cdphe/aqcc-regs 4) The following emissions of non-criteria reportable air pollutants are estimated based upon the process limits as indicated in this permit. This information is listed to inform the operator of the Division's analysis of the specific compounds emitted if the sources operates at the permitted limitations. Equipment AIRS Uncontrolled Controlled ID Point Pollutant CAS # Emissions Emissions (lb/yr) (lb/yr) Benzene 71432 579 29 Toluene 108883 732 37 Ethylbenzene 100414 18 1 Surge Vessel 008 Xylenes 1330207 260 13 n-Hexane 110543 5,923 297 2,2,4- 540841 9 1 Trimethylpentane Note: All non-criteria reportable pollutants in the table above with uncontrolled emission rates above 250 pounds per year (lb/yr)are reportable and may result in annual emission fees based on the most recent Air Pollution Emission Notice. 5) The emission levels contained in this permit are based on the following emission factors: Point 008: Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl NOx 2.07x10-2 2.07x10-2 TNRCC Page 8 of 10 atavik COLORADO Air Pollution Control Division C a3,tmtrlt o Pubis_Ffedirti b nviv.rtme",1 Dedicated to protecting and improving the health and environment of the people of Colorado Uncontrolled Controlled CAS # Pollutant Emission Factors Emission Factors Source lb/bbl lb/bbl CO 4.13x10-2 4.13x10-2 TNRCC VOC 5.885 2.942x10-1 ProMax 71432 Benzene 1.264x10-2 6.318x10-4 ProMax 108883 Toluene 1.597x10-2 7.984x10-4 ProMax 1330207 Xylene 5.666x10-3 2.833x10-4 ProMax 110543 n-Hexane 1.293x10-1 6.467x10-3 ProMax Note: The controlled emissions factors for this point are based on the enclosed combustor control efficiency of 95%. The site specific VOC and HAP emission factors in the table above are based on a site specific pressurized liquid sample and ProMax simulation. The site specific sample used in the ProMax simulation was obtained from the outlet of the low pressure separator for the Thistle Down 31G-332 well on 10/17/2019. The sample pressure and temperature are 24.9 psig and 103°F respectively. The TNRCC Flare Emission Guidance (Technical Supplement 4) NOx and CO emission factors (0.138 lb/MMBtu and 0.2755 lb/MMBtu respectively)in the table above were converted to units of lb/bbl using a GOR of 56.34 and a heat content of 2,660.92 Btu/scf. Actual emissions are calculated by multiplying the emission factors in the table above by the total hydrocarbon liquid throughput routed through the surge vessel during VRU downtime. 6) In accordance with C.R.S. 25-7-114.1, each Air Pollutant Emission Notice (APEN) associated with this permit is valid for a term of five years from the date it was received by the Division. A revised APEN must,be submitted no later than 30 days before the five-year term expires. Please refer to the most recent annual fee invoice to determine the APEN expiration date for each emissions point associated with this permit. For any questions regarding a specific expiration date call the Division at (303)-692-3150. 7) This facility is classified as follows: Applicable Status Requirement Operating Permit Synthetic Minor Source of: VOC, CO tt NOx PSD Synthetic Minor Source of: VOC NANSR Synthetic Minor Source of: VOC Et NOx 8) Full text of the Title 40, Protection of Environment Electronic Code of Federal Regulations can be found at the following website: http://www.ecfr.gov/ Part 60: Standards of Performance for New Stationary Sources NSPS 60.1-End Subpart A - Subpart UUUU NSPS Part 60, Appendixes Appendix A - Appendix I Part 63: National Emission Standards for Hazardous Air Pollutants for Source Categories Page 9 of 10 g , , cOLORADO Air Pollution Control Division GDP HE Deza,irrie,a O Pubf:Health b Envy civne;1 Dedicated to protecting and improving the health and environment of the people of Colorado MACT 63.1-63.599 Subpart A - Subpart Z MACT 63.600-63.1199 Subpart AA - Subpart DDD MACT 63.1200-63.1439 Subpart EEE - Subpart PPP MACT 63.1440-63.6175 Subpart QQQ- Subpart YYYY MACT 63.6580-63.8830 Subpart ZZZZ - Subpart MMMMM MACT 63.8980-End Subpart NNNNN - Subpart XXXXXX Page 10 of 10 C lCzr alk!o Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package H: 421565 Received Date: 10/30/2019 Review Start Date: 4/1/2020 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section Township Range County AIRS ID: 123 NESW 31 5N 64 Plant AIRS ID: A0A5 Facility Name: Thistle Down 31 Sec HZ ' Physical Address/Location: NESQ, 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# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 001 Condensate Tank TK-1 Yes 19WE1027 1 Yes Issuance Section 03-Description of Project PDC Energy,Inc.(PDC)is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non- attainment area.With this application,the operator is requesting permit coverage for a surge vessel,condensate storage vessels,hydrocarbon liquid loadout and engines.The hydrocarbon liquid loadout and engines are requesting general permit coverage.This analysis only evaluates the condensate storage vessels. This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section I1.B.3.a.).Additionally,the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy(CO AQCC Regulation 3,Part B,Section II.D.2.a.). Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements,and the change in VOCemissions as a result of this project is greater than 25 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) ❑ ❑ ❑ O ❑ ❑ Title V Operating Permits(OP) ❑ (] 1 O ❑ OLIO Non-Attainment.New Source Review(NANSR) U U Is this stationary source a major source? No If yes,indicate programs and which pollutants: 502 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) 011100111111 Title V Operating Permits(OP) ❑ ❑ DOD DUO Non-Attainment New Source Review(NANSR) ❑ ❑ Condensate Storage sank(s)Emissions inventor5 Section 0l-Administrative Information 'Facility AlRs ID: :123 4076 001 County Plant Point Section 02-Equipment Description Details Deleted Emissions Unit Eleeven(11)538 barrel fixed roof condensate storage ssels connected via liquid m f ld EmissionD.cd [ontml Device F - ..9 Sf� .. Cotiont Enc„ed Co,m,ustpr(sl 2y Requested Overall VOC&HAP Control Efficiency S: 95 f1 Section 03-Processing Rate information for Emissions Estimates Primary Emisslans-Storage Tank(s) Actual Condensate Throughput .,78,315.0 canals(bbl)per year Requested Permit Limn Throughput r+r 91583,0.0arrek(hbl)Per Year Requested Monthly Throughput= .._ Barrels(bbl)per month Potential to Emlt(PTE)Condensate Throughp.441.44,7447.44?.,! 91,5832 Barrels(bbil per year Secondary Emission-Combustion Device(s) Heat content of waste gas= Btu/scf Volume of wastegaz emitted per BBL of liquids produced= scf/hhl Actual heat content of waste gas routed to combustion device= 13,304.01 MMBTU per year Requested heat comeni of waste gas muted tocombustiou device= MMBTU per year Potential to Emit(PTE)heat content of waste gas routed to combustion device= _,.MMBTU peryear Control Device Number of Combustors: 'y �hy mw Pilot Fuel Use Rate: 15.Cscfh +V'S MMscf/yr Pilot Fuel Gas Heating Value: •1436-,Btu/sef z„MMBTU/yr Section 04-Emissions Factors&Methodologies Will this storagetank emit flash emissions] - _ ProMax Flow Rate 114,479.00 bbl/year Pollutant Flash was lib/hrl Whit Gas Total Waste Gas Source (Ib/ir) Rate(Ib/hr) VOC 55.4109589 21.49315068 PmMax Benzene ,0.132833 0.0322951 PrmMax• Toluene 0.166195 0.0424757 ProMax. Ethylbenzene 0,0040234 0.001=665 ProMax Xylenes 0.0542739 0.01977 PfoMex n-Hexane 123928 0.451D24 ProMax 2,2,4-TMP 0.00183549 0.000655226 -. Promax Emission Factors Condensate Tank Uncontrolled Controlled Pollutant (lb/bbl) (Ib/bbl) Emission Factor Source (condensate (Condensate Throughput) Throughput) VOC "528475 8Re5pecific:EF.(Includes flash) Benzene "1.2636E-02 5reiii=cittc EF.(Includes Nth) Toluene 15000E-02 5RnSpecific0f,Occludes flesh) Ethylbenzene 3.9332E-04 SiteSpecigCe.F.(Includes flesh) Xylene 5.6659E-03 She Sped.:E.F.(Includes flesh) n-Hexane 12934E-01 $l5o Spaciflc ES.(Includes flash) 224TMP 1.9059E-04 otpecific E r.(includes Bash) Control Device Uncontrolled Uncontrolled Pollutant IIb/MMBtu) (Ib/ibi) Emission Factor Source (waste Beet (condensate combusted) Throughput) PM10 0.0075 AP122ebie342(PN110/PM 5) PM2.S 0.00]5 AP-41fiabl 14-2(PM10/PM 2 5) NOx 0.3300 tt0yCL More E I Guidance(NO CO 0.2755 • `TWRGC Elam Emlssans Guidance ICO),„ Pilot Light Emissions Uncontrolled Uncontrolled Pollutant (Ib/MM tul (Ib/MMscf Emission Factor source (Waste Heat (Pilot Gas Combusted) Throughput) • PM10 0:0075 PM2.5 ''0.0075 NOx O.Ofi80 a CO 0.3100 !, R VOC .....0.0054. 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) Uons/yearl 'toes/year) (tons/year) (tone/read (lbs/month) VOC PM10 - NOx CO • Potential to Erna Actual Emissions Requested Permit Limits Hazardous Alt Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled llbs/year) (Ibs/scar) II6s/year) )ibe/year) (Ibs/year) Benzene .. .,... __-. Toluene -. Ethylbenzene _ XYlene _ n-Hexane • 224 TMP Section 00-Regulatory Summary Analysis Regulation 3,Parts A,B -. Regulation 7,Section Xll.C,D E,F - .. Regulation 7,Section 011.4,C .. r.. Regulation],Section XVII.0,C.1,C.3 ..�_.- Regulatlan7,Section XVII.C.2 - •,'Secoun Regulation 6,Part A,NSF)Subpart Kb Regulation 6,Part 0,NIPS Subpart 0000 NSPS Subpart 0000a ... - .... Regulation B,Part E,MACTSubpart (See regulatory applicability worksheet for detailed analysis) core C:\Users\Miaught\Desktop\323.00.05\39WE1027.CP1 Section 07-Initial and Periodic sampling and Testing Requirements Doe the company use the state default emissions factors to estimate emissions? -No If yes,are the uncontrolled actual or requested emissions estimated to be greaterthan or equal to 60 tons VOC per year? --N/A the operator developed site specific emission factors. If yes,the permit will contain en"Initial Compliance"testing requirement to develop a site specific err eviuns factor based on guidelines In PS Memo 05-01. Does the company use aite specific emissions factor to estimate emissions? 'Yes If yes and If there are flash emissions,are the emissions factors based an a pressurized liquid sample drawn at the 3 a'b,, facilhy being permitted?This sample should be considered representative which generally means site-specific and y~r{.:¢',. collected withinone year of the application received date.However,tithe faclrty has not been modified(e.g.,non h'a . welb brought onfne(,then tt may be appropriate to use an older site-specific sample �y, _Yaw If no,the permit wit contain an"Initial Compliance"testing requirement to develop a site specific emsslons factor based on guideline in P5 memo 05-01. Does the company request a control device efficiency greater than 95%for a flare or combustion device? ;Nd tf yes,the permit will canton and initial compliance test condition to demonstrate the destruction efficiency of the combustion device based on inlet and outlet concentration sampling Section 05-Technical Analysis Notes l Typically,the secondary combustion emissions arecatculatedusingthewaste gas flow rate and heat content predcted by the model used to establish the sitespecffic emissions factors.Based on the ProMec simulation the total waste ass flaw rate was predlctedto be0.01767t16MMsdfday(Flash and W&B gas).Additionally,an average heat content was determined using the heat content of the flash gas stream(2641.58Btu/scf)andthe W&B stream(2712.11 Btu/sct/eod the following equations: Average Heat Content:((2641.sggtufscf)•(0.0128259 MMscf/day)/(6.01767126MMscf/day)I a((2?12.11Btu/scir(0.004g4526MMscf/day)/(0.111 7 67 1 1 6MMscf/day}J=2660.9186 etu/scf Using this information,the yearly heat inert of theses would be calculatedasfollows:Heat Input(MMBtu/yr(=(0.1767116 MMscf/day)•(365day/year)•(26609ig6 MMBtu/NMscf)•(76319 bbl(year)/(114479661/year(=13,441.E53MMetu/year.Using thh value,the actual NOz and CO emissions would he calculated at 0.79 tpy and 1.58 tpy rasp cUvey. The operator used the fallowing equation to calculate the actual annual heat input Heat Input(MMetu/yr)=(Uncontrolled VOC(ton/ye)r(20001b/ton(/[MW(lbtlb-monr[379.41 sd/lh-mota[1Nocmol %r(Heat Content(Bto/scf)311.MMatu/1,000,000 Btu).The operator eapressed the valuesfer molecularweight and VOC mot%used in the equation were obtained from the flash gas stream and(helmet content was obtainedfrom the average of the flash gas stream and the W&Bstream in the ProMaz simulation provided in the application.The values used in the equation areas follow:(I)Molecular weight:47.1122 (ii)VOC mot%:72A1629147%,(lil)Heat Content 2660.9188 Btu/sd.Using these value,the operator calculated a heat Input of 13,364.01 MMBtu/yr.Since this value is mom conservatNe than the value calculated above using prescribed methods,it will be used for permitting purposes. 2,The it parties sample usedtoYFbhhh emissions factors for thlssourceobtained within a year ofth ppil t Thsample was obtained from the Thistle Down 31G332 well o 10/17/2019 This well Is one of the ten new wells drilled atthts facility.As a result,the permit will not require Initial testing in order to obtain site specif sample.It should be tilled that the sample Include sample probe temperature and pressure In with gauge pressure and temperature.Acording to lab infomreton,the Sample probe temperature and pressure are obtained using lab equipment during the sampling process.These vale.areezpectedto be more accuratecompared to the gauge values and are acceptableforuse In the simulatlan to establish saespecificemssian factors. 3.Please referencethe APEN submitted on 10/30/19 fora list of the ten new welts atth's facllity.The wells associatedwhh this tank battery were fractured in Icily 2019 and began production in August 2019.Nine wells produce from the Niobrara formation and one produces from a commingled stream from the Niobrara,Fort Hays,Carllle and Cadet formation. 4.The permit will not contain initial orpedodic opacity tenting forth.enclosed combustor(s)because the 0&M plan approved for this source requires weekly visible emissions observations of the enclosed oombustor(s). 5.Emission factors forethylbenzenc and 2,2,4-IMP will not be included in the permit because emissions are below APEN reporting thresholds(I.e.0250.Ib/year},. 6.The operator provided the follow.ingmformation regarding the 300 bpi LO control tank listed on the facility diagram:The vesselon the foeilirydiogram labeled"300641 LO Control Tank"Is the knockout tank for the focifltyslaadau./lore.Vdpors from truckload ut ore first routedtathls tank,and then to theffarededi,oted to controilingloadout activities.Any ermssions associated with this tank are rountedfor4y the loadouCernissians It not normal operation for ANytondensate to enter this tank.In the unlikelyeventirquid condensate occurs withm the took,either from the condensing of vapors or the.flooding of the tank-track vaporline due to overfllling,the liquid Is imm edratelytransferredfrom the knockout.*to the condensate storage foks.TAs information indicates any potential emissions associated with this vessel.are:appropriately accounted for In the application. 1.A throughput limit is included in the permit for pilot combustion.Emisson factors and calculation methods for pilot light combustion emissions are also included in the notes to permit holder.This information is included in the permit because pilot light emisslons cmrttibute to the overall emissions from this source.AddaWnally R b important to include this infmmation because throughput tracking and emission calculation methods are different than those used to estimate emssons based on the condersatethmughput.This clarity is important for accarateiyguntifying actual emissions at this facility. 8,According to the application,"The hydrocarbon liquid flows to a surge vessel,which further separates the fluid phese.The hydrocarbon liquid then fowsto a third party pipeline to besold via a lease Automatic Custody Transfer(LhCI}unit.At time when the surge vessel is not operational,the condensate flows to eteren(11)538 bbl condensate storage vessels.The tank vapors are sent to the enclosed combustors."Bxsedon thefaciity design,emissions occur when the hydrocarbon liquid h sent to thestarage vessels rather than the surge vessels and when thesurge umsei VR0 is down.ewes determined that the storage vessels ardsurge vessel do not meet the APEN grouping requirements and must be permitted separately.This determination was made fora couple reasons.First of which is that the surge vessel and starago Vessels are two distinct emitting rinks that have different control scenarios and distinct throughput values.Further,the regulatoryapplicability for the storagevesseis s distinctly different from that of thesurge vessel.The surg vessels not classified or defined as a storage vessel and would therefore not be regulated as such under NSPS BA,NSP50000/00000 or Regulation 7.Instead,the surge vessel would be classified as a seporatorfor Regulation l requirements This permit only address.the throughput routed to the storage vessels and the resulting missions.Based on the facility description and discussions with the operator,the hydrocarbon liquid b sent directly to the storage vessels during surge vessel and 1ACT downtime.The hydrocarbon liquid is never routed to the surge vessel prior to being routed to theworage veseb.The operator Indicated that the surgevessei condensate throughput and condensate throughput routed directly to the storage vessels aredbtfnct and tracked separately. 9.The operator indicatedthatt£ieir6CADA system distinctly measures the volume of hydrocarbon liquid sent to either the surge vessel or the storage vessels.Asa result,the hydroarbon liquid throughput for the surge vessel and storage vessels an be determined independently and accurately. 10.in the event the surge vessel k not operational and/or the tACf unhis notavailable,the operator indicated that the hydrocarbon liquid from the Inlet separators a routed directly to the storage vessels.Due tothefacliity design,theseespecific sample used to develop emission factors and estimate emissions was deemed acceptable because it was taken from the oullet of the heated separator forth.Thistle Down 316-332wett.Smce the sample was taken from theouttet n£the separatorthat sends liquid directly to the storage vessels,initial sampling a not required in the permit. 11.The operator provided a copy of the eN05 that was submitted electronically to the Division for thls source on 03/26/2020.As a result,the standard condrtion requiring submittal of a Notee of Startup forties source upon bsuance of the permit was removed from the permit. 12.Thissource is not subject tathe measurement system requirements in Regulation 7 Part['Section ll.C.4 beeauseths000rage vessels were constructed before 05/01/2020. 9; 13.The operator was provided with a draft permit and APEN redline to review pdorto public comment The operator reviewed both documents and expressed they had no comments. s n Section 09-Inventory SCC Coding and Emissions Factors Uncontrolled E AIRS Pointe Processf SCC Code Pollutant Factor s Control%Units 01 4.04-003.11 Plead Roof lank,dondensate,work rig*breaohing•W hingiossec PMro b/1,000.gallons condensate throughput PM25 _ b/1,000 gallons condensate throughput NOx. - b/1,000 gallons condensate throughput Vat _-, b/1,000 gallons condensate throughput - b/1,000 gallons condensate throughput Benzene _._ _ b/1,000 gallons condensate throughput Toluene b/1,000 gallons condensate throughput Ethylbervene 6/1,000 gallons condensate throughput %ylene b/1,000 gallons condensate throughput n-Hexane - b/1,000 gallons condensate throughput 224 TMP .. 6/1,000 gallons condensate throughput 3 of 4 C:\Users\hslaught\Desktop\123A0A5\19WE1027.CP1 • Condensate Tank kegulatory Analysis Worksheet The regulatory requirements below ore determined based on requested emissions. wlemn egmmme.+ Arrubmabrr 1.Are uncontrell. m arrycrlt. IncINIdual source greater..xTPy(Regulation a,Pan0.senon 01aP • x aNtotalf e I )Mor 1eA/ na Munn 05-01and ywame enar+rrdlnkrappueabP tml • 1 Are total famrtyan r++Ire ,Py.N TOTPyerw enxxwaetiterthan lgyPy(Papist. �,.. _., tutu tutu tutu_tutu...tutu Areunmmraled eblion.hit ymrera bohnane'remthe mdr.dualsourcegretertbanlrPr lRegr Iwrl,PanA.sdinn ll.la)x - . .ue= w anAPw.aetp the g gn is.e construction date ben/Iced.)pler to 1.7.120111101 and not modified a...24MM[See PSMenod5Ultldin.orel.lzand,10 and see..for zddnleNl&Mem dhgnntlr Mastmeleshesei Areta uncontrolled vac emirs(n greater than zTPY, greater than s TPy o'COemissions greater MT.lbegulalen s,pane,senlonll0.zll Yes source...a permit al facblN unm oa xoa mt at t 1.Is ibis age panel .Mara rao m. ulna.,gas dnP tlonx b nu inalatdmefap ltvtro n plat pryen n+Fat. 2.Is tbIssteragetank located al erpbratoperation',11 tualgm=mpr..o.tatmnmnat uh&tl umm ry M1 Tea cue sactlo.a.C.1-,eneral Requirements(or Ion control boupmen-Pmentlon of Leakage section x11.5-R=ontFaylne and beta.. Is tbisstoragetank located In the a.hr wane control area or any ownenon....rnent anahaveunmntrm uncontrolled e?+than or Istoa¢e anklsnotsuyeet tag auon7b=gll.0 yeu 7=tdtaedbytnT.on pgen sumarv+M1m. s.�t ,ll=t aslemnslola to pers«a wc? NA storage Section XII.C.1 gal Requirements for AerPdI..Control boufpment-Prevention al Leakage SeatIgggndeoR.eb.le[Ipn>,se-Emission .geaslI orlon Procedures Is...located a donisto dllry5 • our have m tM1ea ntM1.Pmlat a 1.Is tills mndenatestoagelaM'+located mob..and produnlononeauan,well prod..taallry`,natural gas co... gas pmmssingplant? •', Go to the nekt pu.lon-You bave Indicated lacIlltyrypean project summary sheet. • o.Ate rm ,Id sr rarer err erns m ac s per year v ? va mute l+subject w m evl of Regulation x,5loi+ l.B.C.Go lathe non question uncontrolled baction ®rake<gne eoulmmmsdn P.vhom s oe.the condensate n M Ixo Ispune+subject to all provIslom of Regulation?satwnxvl.mbtatbmeac Saction -Capture and MonaorIng ler Storage-ranks fitted'v..Pollution Control Equipment or quagn.o 1. tne Individual stone vessel mqc maes(m)1ax eeL+V Yes Oa to the next E.0m+ Mloll wN¢aw greater equal to Yes • smrnee rank is na:us.61=n xsPsgb. a. esethesvessel Faso deg.capacity less..oregwl tot,sas.5.m',10,000 geL)used for petroleum'or note stored proem.,or tradpd torts custody trans. dlrc as dtl In a0.111h, ruaci,raon+trunea,w modmed ore dembt R ns no C,a0a)aterlvby xs,leer condensate 4.Do..etan4 5.Does the storage vessel storoa a vessel"' 60.111137 e? NA a.ba+ nelerthemlw,mgadanl...env...11 designed to rP.(9e ppand ernisslons to the aunospbereI50 obldlRddx:o h.The design gap m'195a bull an .Oa la0.gblbld?r or • c.The tlm4n capacity a ereatatban or equal.n NA'ran ggq boles than151 m'(950 no and atom Mold walla mamwm true vapor pressure bas Wit ssaLPala0llpgb)I?stomge tank meet memo..Iran a.The tlerIgn capacl,greatertlian or to 151 50 ual T grealerlhan or m l.xsNer97n eey)bublas thank(m')9500Rq am ewes a bgudwwith a mabnum toeevaportpc...grate,..0..1 mis.o FP,but less than 2,5 NPa, xA xA tutu.��b.meea tutu................�, I • AOCFP,Part av,subpart 0000100ow standards&Perforance for crude ail end Netureiae+Prod..Ta.mlelonend • Olaxbulan la a+d located at a ladlltymsbeo.hoteall and natural gas PdaLonsegment,natural gas processing segment or natural eastan+.¢sloe anastora¢e segment tithe industry? cominue. wy d..the source categon..)m a.Was this condenatestoragevessel const.ted.leconstnacted, d summarvaiwa. (see deMR..aO rm bay.,sO.z) 5epenberzs,xoTn vsugect sPs 0000 Go net question to continue dnermwnen n xsPs 0000a applIcah.y. s r�am,w tad I=a 0al massponbe Ts,sass? Yea Go to nest question Areepta ems+ort.r sro age ianF ls not sugm NLspsoo00a. 050/60sa3oia? a,etMa . non cool m req emau der+ g gm.eb haOcw PartwsubpartebwaOcm Pgas pa vex? NA + [Note:If+storage venal I+previously determleed to be subject to NSP50000/00000 due.umbels..above s tons.pevo0 on.appliubllity...nation date,it should'amain subj.to N5P5000D/0000a pre aosaaslellxl/ao.szasgelkl ay.11,34..1 vac emdmionz drop below+tons pa veer) 40 CR Pare 33 Suboarl HOP and.•P.duelen.ibtlea Is me storage tan.acated at.o an nuuyua herol.elonowlne nr.m. Ieontbnue you have ndrca..source ateysry an Ole Pmlectsonmary rhea. a.A!1.wt p.mse,elatladles or+tel...donallutli lbg.?w(al(xll:o natural gas pier.tile poin=t whl.natua e l gasers.naturalgas tnrumudonanel eton¢=soura aearryohddxedmagnalwdu+tar 1.3,..141311,r b 2.Is the tan b located at a faelltytbat+majorxAPe?mm Storage,.isnot subject.onxx-There are no MALT vend rqubenemsfc.a.at area seen. 3.Does theta,.meet the clerfnItIon 01,1,am...63,17 NA with thepaern al. 5.Is Met O, w au ebs.r hpan 0000? NA tank subjectts. Pan 6 I-.t.,.. subpar,General Muu e.3.?ea(al Ta lea gss.ns.Munkodngon Control Standards ess.na•RemmkeuMng 463.775•Reporting • Tres document assbls opealws teals delemnum appltaWTify of*Warn requeumeres lihe clean AVAeI.es ympkrrendrgrryuy5Ums,aMAapmky CeeMMCmuseMs n reeuyabans.225 deg menx a nod a rule op-mgt./me Meanaysb IePPes boa individual eels s.TVls echo./a me,mum egalh messmp reyubemenl and is nod legally...sea.In Mee eueenl ore romtufbenseee Me language Nleis document anddlhe language of Clean MAct,its,,tumnhrg Curably Conbol Commission language of Mesl o regulaion wig rend.The use of n50005 may+lay langeseesusees•musenmend." ."shouk.-aM-caa, lded to ate.APCO Inlapela5ons and recommendations.Mandalay te'mnologysuch as"me end'femme aninlendal to descnbemneolbne ragmen'..uncles Ma terms of Me Clean AV Acl and Air quarry control Commission regulations,buf M5 document does nab esleMse legate,binding requirement n ante of 02511 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 7/13/2020 Plant AIRS ID A0A5 Ozone Status Non-Attainment Facility Name Thistle Down 31 Sec HZ EMISSIONS-Uncontrolled(tons per year) EMISSIONS With Controls(tons per year) POINT PERMIT Description PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total PM10 PM2.5 H2S SO2 NOx VOC Fug CO Total REMARKS AIRS ID VOC HAPs VOC HAPs Previous FACILITY TOTAL 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total Previous Permitted Facility total 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 New Facility-No Previous Total 007 GP10 0.0 0.0 This point is irrelevant as the sources covered by it have already been permitted and covered under points 001-006&008.This point wilt not be processed. XA Ten(10)0.75 MMBtu/hr Heaters 0.3 0.3 0.0 3.6 0.1 3.0 0.0 0.3 0.3 0.0 3.6 0.1 3.0 0.0 Insignificant Source XA Fugitives 0.2 0.0 0.2 0.0 Insignificant Source XA Produced water storage vessels 0.5 0.1 0.5 0.1 Insignificant Source XA Sandtrap drain tank 0.4 0.0 0,4 0.0 Insignificant Source FACILITY TOTAL 0.8 0.8 0.0 0.0 68.0 427.7 0.2 105.0 13.2 0.8 0.8 0.0 0.0 11.4 35.5 0.2 18.3 2.2 VOC: Syn Minor(PSD,NANSR and OP) NOx:Syn Minor(NANSR and OP) CO: Syn Minor(OP) HAPS: True Minor HH: Area source-no affected sources ZZZZ: Area source Permitted Facility Total 0.6 0.6 0.0 0,0 64.4 426.7 0.0 102.0 13.1 0,6 0.6 0.0 0.0 7.8 34.5 0.0 15.3 2.1 Excludes units exempt from permits/HPENs (A)Change in Permitted Emissions 0.6 0.6 0.0 0.0 7.8 34.5 0.0 15,3 Modeling not required based on A change in emissions.Pubcom is required b/c new syn minor limits are being established and the change in VOC emissions is greater than 25 tpy. Total VOC Facility Emissions(point and fugitive) 35.7 Facility is eligible for GP02 because<90 tpy(CO) and 45 tpy(NOx&VOC) (4)Change in Total Permitted VOC emissions(point and fugitive) 34.5 Project emissions greater than 25 tpy VOC Note 1 Note 2 Page I of 2 Printed 7/22/2(121) C(1LORAIX)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 A0A5 Facility Name Thistle Down 31 Sec HZ Emissions-uncontrolled(lbs per year) POINT'PERMIT IDesoription Formaldehyde Acetaldehyde Aorolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224 TMP H2S TOTAL(ipy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 001 19WE1027 Eleven(11)538 bbl fixed roof 1158 1463 .36 519 11846 18 7.5 condensate storage vessels 002 GP07 Hydrocarbon loadout 57.1 I 495.9 0.3 003 GP02 SI RICE Cummins G855,4SRB,178 274.9 37 4 35 3 21 2 41 0.2 HP(site rated),SN:25436759 004 GP02 SI RICE Caterpillar G3306NA,4SRB, 768.3 31 3 29 5 17 7 34 3 0.4 137 HP(site rated),SN:G6X07244 005 GP02 SI RICE Caterpillar G3306NA,4SRB, 768.3 31.3 295 17 7 34 3 0.4 137 HP(site rated),SN:R6002701 006 GP02 SI RICE Caterpillar G3306NA,4SRB, 768.3 31 3 29 5 17 7 34.3 0.4 137 HP(site rated),SN:56X089665 007 GP70 .. 0.0.. 008 20WE0603 Natural gas flaring from one(1)surge 579 732 i8 260 5923 9 3.8 vessel during VRU downtime. XA Ten(10)0.75 MMBtu/hr Heaters 0.0 XA Fugitives 9.5 95 92 9.3 11 0.0 XA Produced water storage vessels 42 48 I 1 10 8 11.8 0.1 XA Sandtrap drain tank 3.8 18 0.0 TOTAL(tpy) 1.3 0.1 0.1 1.0 1.1 0.0 0.4 9.2 0.1 0.0 0.0 0.0 13.2 *Total Reportable=all HAPs where uncontrolled emissions>de minimus values Red Text uncontrolled emissions.de nrnunus Emissions with controls(lbs per year) POINT'PERMIT 'Description Formaldehyde Acetaldehyde Acrolein Benzene Toluene Ethylbenzene Xylenes n-Hexane McOH 224TMP H2S TOTAL(tpy) Previous FACILITY TOTAL 0 0 0 0 0 0 0 0 0 0 0 0 0.0 m 001 19WE1027 Eleven(11)538 bbl fixed roof 58 74 2 26 593 1 0.4 condensate storage vessels 002 GP07 Hydrocarbon loadout 29 24.8 0.0 003 GP02 SI RICE Cummins G855,4SRB,178 274.9 37 4 353 21 2 41 0.2 HP(site rated),SN:25436759 004 GP02 SI RICE Caterpillar G3306NA,4SRB, 768.3 31 3 25 5 17.7 34 3 0.4 137 HP(site rated),SN:66X07244 005 GP02 SI RICE Caterpillar G3306NA,4SRB, 768.3 31 3 29 5 17; 34.3 0.4 137 HP(site rated),SN:R6502701 006 GP02 SI RICE Caterpillar G3306NA,4SRB, 768.3 31.3 29.5 17.7 34,3 0.4 137 HP(site rated),SN:66X089665 _. ___._ _ __ _ .. .. 0.0. 008 20WE0603 Natural gas flaring from one(1)surge 29 37 I 13 29/ I 0.2 vessel during VRU downtime. XA Ten(10)0.75 MMBtu/hr Heaters 0.0 XA Fugitives 5 5 9 5 9.2 9.3 11 0.0 XA Produced water storage vessels 42 48 1 1 10 8 11 8 0.1 XA Sandtrap drain tank 3 8 16 0.0 TOTAL(toy) 1.3 0.1 0.1 0.1 0.1 0.0 0.0 0,5 0.1 0.0 0.0 0.0 2.2 2 123A(IA5 7/22/202(1 Colorado Air Permitting Project PRELIMINARY ANALYSIS-PROJECT SUMMARY Project Details For Division Use Only Review Engineer: Harrison Slaughter Package tf: 433126 Received Date: 7/6/2020. Review Start Date: 7/9/2020 Section 01-Facility Information Company Name: PDC Energy,Inc. Quadrant Section Township Range County AIRS ID: 123 NESW 31 5N 64 Plant AIRS ID: A0AS Facility Name: Thistle Down 31 Sec HZ Physical Address/Location: 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# (Leave blank unless Emissions (Leave blank unless Issuance Self Cert Engineering APCD has already Emissions Source Type Equipment Name Action Control? APCD has already # Required? Remarks assigned) assigned) Permit Initial 008 Separator Venting Surge Vessel' Yes 20WE0603 1 Yes Issuance Section 03-Description of Project PDC Energy,Inc.(PDC)is requesting permit coverage for several sources at a new synthetic minor oil and gas well production facility located in the ozone non- attainment area.With this application,the operator is requesting permit coverage for a surge vessel,condensate storage vessels,hydrocarbon liquid loadout and engines.The hydrocarbon liquid loadout and engines are requesting general permit coverage.This analysis only evaluates the surge vessel. This source is APEN required because uncontrolled actual VOC emissions are greater than 1 tpy(CO AQCC Regulation 3,Part A,Section II.B.3.a.).Additionally, the source is permit required because the uncontrolled VOC emissions from all APEN required sources at the facility are greater than 2 tpy(CO AQCC Regulation 3,Part B,Section Public comment is required for this source because new synthetic minor limits are being established in order avoid other requirements,and the change in VOC emissions as a result of this project is greater than 25 tpy. Sections 04,05&06-For Division Use Only Section 04-Public Comment Requirements Is Public Comment Required? Yes If yes,why? Requesting Synthetic Minor.Permit Section 05-Ambient Air Impact Analysis Requiremer Was a quantitative modeling analysis required? No If yes,for what pollutants? If yes,attach a copy of Technical Services Unit modeling results summary. Section 06-Facility-Wide Stationary Source Classification Is this stationary source a true minor? No Is this stationary source a synthetic minor? Yes If yes,indicate programs and which pollutants: 5O2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O O CI O O Title V Operating Permits(OP) O O E O O O O Non-Attainment New Source Review(NANSR) Is this stationary source a major source? No If yes,indicate programs and which pollutants: SO2 NOx CO VOC PM2.5 PM10 TSP HAPs Prevention of Significant Deterioration(PSD) O O ❑ O O ❑ Title V Operating Permits(OP) ❑ O O O O O O O Non-Attainment New Source Review(NANSR) O O Separator Vent'ng Emissions Invent-o • Section 01-Administrative Information IFacllity 10: s 123 ADAS 008 Al Rs County Plant Point Section 02-Equipment Description Details Natural gee Oaring from 000(1)surge vesseld ring vapor recovery unit)VRU)downbme Detailed Emissions Unit Description' Enclosed Combustor(s) Emission Control Device Description: Requested Overall VOC&HAP Control Efficiency h: 95 Limited Process Parameter Liquid Throhghput Section 03-Processing Rate Information for Emissions Estimates Primary Emissions-Separator Actual Throughput= 38,160 Barrels(bbl)per year Requested Permit Limit Throughput= 45,792 Barrels(bbl)per year Requested Monthly Throughput= ;__"... Barrels(bbl)per month Potential to Emit(PTE)Throughput= Barrels(bbl)per year Secondary Emissions-Combustion Device(s)for Air Pollution Control Separator Gas Heating Value: 2660.9 Btu/scf Volume of waste gas emitted per BBL of liquids throughput: 50.3 sc₹/bbl Control Device I I Pilot Fuel Use Rate: scfh MMscf/yr Pilot Fuel Gas Heating Value: Btu/scf Section 04-Emissions Factors&Methodologies Description Liquid produced by the ten(10)wells flows to ten(10)inlet three-phase separators.The liquid from the three-phase separators is then routed to a surge vezeel which further separates the fluid phase.The hydrocarbon liquid from the surge vessel then flows to a third party pipeline to be sold via a Lease Automatic Custody Transfer(LACE)unit During VRU downtime,surge vessel emissions are routed to the storage vessel vapor manifold and controlled with the condensate storage vesselemissions.Emission factors for this sou.were calculated using a site specific pressurized liquid sample obtained from the outlet of the Inlet three-phase separator for the Thistle Down well 310-332 on 10/17/2019 in conjunction with ProMax.The sample temperature and pressure are 103°F and 24.9 pslg respectively.As discussed in Section 08,the emission factors used for this source reflect the emission factors developed for the condensate storage vessels and constitute conservative estimate of emissions.Values from the ProMax simulation are shown in the table below. ProMax Flow Rate 114,479.00 bbl/year Total Waste Gas Rate Pollutant Flash Gas(ll/hr) W&B Gas(lb/hr) Source Ob/hr) VOC 55.4109589 X2149315060 `...... ProMax Benzene 0.132533 0.0322951 ProMax Toluene 0.166195 0.0424797 ProMax Ethylbenzene 0.0040234 0.00111665 ProMax Xylenes 0.054939 0.01977 ProMax n.Hexane 123928 0.451024 ProMax 2,2,4-IMP 0.00183549 0.000655226 ... ProMax Emission Factors Separator Venting Uncontrolled Controlled (lb/bbl) (lb/bbl) Emission Factor Source Pollutant (Liquid Throughput) (Liquid Throughput) VOC Benzene 63172x. ProMax Toluene _ 9238@-04 ProM Ethylbenzene Js _ 1;967E-OS ProMax Xylene 2033E-04 ProMex n-Hexane 6.467E-03 ProM 224 TMP Primary Control Device Uncontrolled Uncontrolled Pollutant )Ib/MMBtul lb/bbl Emission Factor Source (Waste Heat Combusted) (Gas Throughput) PM10 2,4P.42 Table 1:42(PM1A/PM.ZS) PM2.5 0.0005 '":AP-42Table 1.4-2(PM10/PM.25): SOx 0.0®6 ¢q AP 421 Into 142)50) NGx_ 0.3380 7., _ Emissions Guidance(NOx, CO 0.2755 3'. re.Emissions Guidance(COI -;a Pilot Light Emissions Uncontrolled Uncontrolled Pollutant )Ib/MMBtu) Ib/MMscf Emission Factor Source (Waste Heat Combusted) (Pilot Gas Throughput) PM10 PM2.5 C.-0000 SOx 0.0320 NOx 0.0000 VOC 0.0000 CO 0.0000 1.51.i4eu0 Section 05-Emissions Inventory Potential to Emit Actual Emissions Requested Permit Limits Requested Monthly Limits Criteria Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled Controlled (tans/year) (tans/year) (tons/year) (tons/year) (tons/year) (Ibs/morsh) PM10 0.021 v.u... _. 4.044 PM2.5 0.021 _.�__ 500 .:.,_ 0.002 Non .�4tI 039475 VOC ..,: ._:.233 ...v.. _ CO 150 Potential to Emit Actual Emissions Requested Permit Limits Hazardous Air Pollutants Uncontrolled Uncontrolled Controlled Uncontrolled Controlled (Ibs/year) Ili./Year) llbs/geed )Ibs/year) (lls/year) Benzene Toluene 731.14 _ Ethylbenzene 10.01 - 0 Xylene 25•]..15 ,_ . ___ n-Hera _:88 _F94a04 224 TMP S"r'3 0.27 ..... 3.720 -. 2 of 4 C:\Users\hsleught\Desktop\123AOA5\2OW E0603.CPI Section 06-Regulatory Summary Analysis Regulation 3,Parts A,B Regulation],Part O,Section 11.8,E --. __ '.5 t ii .2.- Regulation?,Part D Section II.B.2.e _i _f... ,.= s -_s„i (See regulatory applicability worksheet for detailed analysis) Section 07-Initial and Periodic Sampling and Testing Requirements *SEW21afeNtWaR1W:M4WVaiErWOMO,;,5e,;OMAN! .. y:.....,. s:..' ..t .. .. i, VOWAraraggfAataKCIOADRONTOINAW4NOMPONSMARAMIANIMMOiSagliagigNIXOAPPWAP*OWN7090 IfterrrarrfVierriAreiws. d Oro 0 "blind +v'9,V ,oe 5iD,"-olorod;3's:od mor,,,o,. n",kn ° n.'v, Using Liquid Throughput to Monitor Compliance Does the company use site specific emission factors based one pressurized liquid sample(Sampled upstream f th , equipment covered under this Al0.s ID)and process simulation to estimate emissions? This sample should have been collected within one year of the application received date.However,if the facil'ny has not been modified(e.g., no new wells brought on-line),then it may be appropriate to use en alder site-specific sample. If no,the permit will contain an"Initial Compliance testing requirement to collect a site-specific liquid sample and conduct an emission factor analysis to demonstrate that the emission factors are less than or equal to the emissions factors established withthipplication. Does the company request a control device effciency greater than 95%for a flare or combustion device? No _ If yes,the permit will contain initial and periodic compliance testing in accordance with PS Memo 20-02 Section 00-Technical Analysis Notes 1,The site specdicsample used to establish emissions factors forth s source was obtained w thing year of the app.cation The sample was obtained from the Thistle Down 313-332 well on 10/1]/2019 This wells one of.he ten new wells drilled at this facility.As result,the permit will not requre Initial toting in order to obtain a site specfesampla It should be noted that the sample,ncludessample probe temperatureand pressure in conjunctonw,th gauge pressure and temperature.According to lab infornsaton,the:sample probe temperature and pressure re obtained using lab equi pment during the sampling process.Thesevalues are etpectedto be more accurate compared to the gauge values and are acceptable for use In thesmulationto establishste spec ficemssion factors. 2.Please referencetheAPENsubmittedon 10/30/19 for alist of the ten new wells at th c facility.The wells associated with the tank battery werefractured in July 2019 end began production in August 2019.N a wells produce from the bhobrara thrmation and one produces from a commingled stream from the Niobrara,Fort Hays,Caring and Codell formation 3.The permit will not contan'ntal or pen odic opacity testing for the enclosed combrstorls)because the 0&M plan approved forthis source requwes weekly visible emsson observatonsof the enclosed combustor(s). 4.Emssionfacorsforethylbenzene and 2,2,4-TMP wilt not be included in the oemla because emissions are below APEN reporting thresholds(i,e.<250 lb/year). S.During VRU downtime,the surge ssel Is controlled by thesame enclosed combustors used to control storage vessel sions According to engineering go dance,the pilot light emissions are grouped with the highest emitting source controlled by the common controldevice.In the cas,h storage vessels are the highest emitting source.As a result pilot light emssons are accounted forwith the stofagevessels)19WE1022)and notthic analysis. 6.Accordingto engnergudance,thetotal combustion emissions(ie.NOx and CO)from all the sources controlled by a common coMmi deuce should be added together for evaluation against APEN reporting thresholds.In thy case NOx and CO embsions from the surge vessel are below APENthresholds.However,total NOx and CO emissbnsfrom all the sources controlled by the enclosed combustors(re storagevesselsand urgevessel)are above APEN-reporting thresholds.As a result allthesturces controlled by common control device wall includelmts on both NOx and CO emissions. 7.In orderto calculatesurgevessel emissions,the operator is using the emission factors established for the condensatestorage vessel,Those emission factors were deemed acceptable and c . for the following reasons(i)The operator the surgevssels not usedto tore condensate prior to sending the Iiquidnothe LACr.This is supported by the informatonthatthis condensateis.routeddirectlyto the storage vessels in the event that the LACTis not available.At a result,.the omis lonsfromthe"surgevesseldo'not include working and breathing emissions in actual operaton.The emission factors developed for the condensate storage vessels do includeworking and breathing emissions.(1)Futther,ehe operatorindicatedthat the surge vessel usually operates between 46psig,whereas the stomgevessels operate at essentially amb'ent pressure(0 psig).The ProMaxsmulaton models flash emissonsthet occur from 37,4psiato 12.5 psfa.Since the surgevessel operates:at a higherpessure,the flash emissions are likely less than what was modeled by the ProMax simulator for the storagevessolt B.According totheepplcation,'The hydrocarbon liquid flows to a surge vessel,which f rtherseparatesthefluid phase:Toe hydrocarbon liquid then flows to a third party pipeline to be sold via a tease Automat cCustody Transfer(LACI) unit.Attmes when the surge vessel isnotoperetionI,the condensatfowsto eleven(11)538 bbl condensate storagvessels.The tank vapors are sent to the enclosed combustors`eased on the facilitydesign,emissions occur when the hydrocarbon liquid is sent to the storage vessels rather than the surge vessel and whenthesurge vessel VRU is down:Itwasdeterminedthat the storage vessels and surgevessel do not meet theAPEN grouping requirements and must be permited separately.This determl tlonwas made for a couple reasons.First of which is that thesurge vessel and storagevessels are two distinct emitting units that have different control scenarios and distincithroughput values Further, the regulatory applicability for the storage vessels isdstnctlydifferent from that of the s rgevessel.Th rge vessel is nm classified or defined as a storage vesseland wouldtherefore not beregulated as such under NSPS I(b,NSP6 0000/0000a or Regulation].Instead,thesurgev ssel would be classified as a separator'for Regulation requirements-This permtonly addresses the throughput routed t th surgevessel and the resulting emissions..ince emissions only resultduringuRUdowntime,the permit will contain a VRU downtime tracking condition. 9.The operato,ndcatedthat their SCADA system dstltctlymeasu-es the volume of hydrocarbon liquid sent to ether the,-urge vessel orthe storage vessels.As a result,the hydrocarbon liqudthroughpu'.for the suge vessel and storage sselscan be determined independently and accurately. 10 Traddlonall/,separator sources with emissions greater than 100 toy are required to use a flow meter and gas throughput for ongoing c npince demonstrations In this case,the facility is designed such that.he embs onsfrom the ugevessel are routedto the cond nsatestorage vesselvapor manifold and are controlled in conjunction with the condensate storage vessel emissions Based on the facility design,retroactive lnstxlleton of flow meters not feasible and would not provide of differentiating storagevessel emissionsfrom eurgeve_sei emissions.Additionally,the opemtor's bong overly c I latingemiss ce they are using the emissionfactors developed for the st orage ea els Finally,the operator aready has am na of accuratelyquanefyingthelqudthroughput for the surgevessel.Based oo the ,it was determinedthat lquidthroughput was a viable option for demonstratngongomg compliance. 11.The operator was providedwth a draft permit and APEN redline to review prior to pubic comment.The operator reviewed both documents expressed they had one comment on the draft permit The operator comment and Division response are as follows(I)Comment; e reviewed the draft permits and APEN redlines for Thistle Down,and only have one comment Can the NOS permit condition in permit 20WE0603 please be removed?Both a paper copy and a digital NOS were also submittedfor the source with the digital submittal receipt attached f your reference (i)Response Thank you for providing a copy of the cempletedeNOt.Since a complete cR05 has been subm0ted,the NOS condition will be removed from the permit as requested. Section 09-SCC Coding and Emissions Factors(For Inventory Use Only} AIRS Point# Process# SCC Code Pollutant Uncontrolled Emissions Factor Control% Unes 000 01 PM10 PM25 _.`. .. NOx ,. VOC CO Benzene _2,6 Toluene 16.0 Ethylbenzene 0.4 ., ,... xylene n-Hexaner. .5 224 TMP • 3 of 4 C:\Users\hslaught\Desktop\123A0A5\20WE0603.CP1 Separator Venting Regulatory Analysis Worksheet The regulatory requirements below are determined based on requested emissions. Colorado Regulation 3 Parts A and B-APEN and Permit Requirements Sour.,c di.ih tTa;,:iJ,.,,lartetr,rrrer,Y Arcs ATTAINMENT 1. Are uncontrolled actual emissions from any criteria pollutants from this individual source greater than 2 TPY(Regulation 3,Part A,Section II.D.1.a)? 2, Are total facility uncontrolled VQC emissions greater than S TPY,NOx greater than 10 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,.5nction 11,13)? IYq[,n.we.,nd,C,,,eU ll,dt;Uxvrcr2 Il,rr t0,'Noo.AtraH,e,',t tIl,0., NON-ATTAINMENT 1. Are uncontrolled emissions from any criteria pollutants from this individual source greater than 1TPY(Regulation 3,Part A,Section 1111 )? Yes• ..1 Source Requires an ADEN.Go to the next question 2. Are total facility uncontrolled VOC emissions from the greater than 2.TPY,NOo greater than 5 TPY or CO emissions greater than 10 TPY(Regulation 3,Part B,Section 1LD,2)? 505 ,'•Source Requires a permit j5,..cacipi,,,,rws,r ,,,r, Colorado Regulation 7,Part D,Section II L Was the well newly constructed,hydraulically fractured,or recompleted on or after August 1,2014? Yes jt1Source is subject,go to next question burr,e ,,,,l,irw'Vn12r:gm .. `.{'e¢^!„•..• n. .:i Section 11.8.2—General Provisions for Air Pollution Control Equipment Used to Comply with Section 11 Section II.F-Control of emissions from well production facilities Alternative Emissions Control(Optional Section) a. Is this separator controlled by a back-up or alternate combustion device(i.e.,not the primary control device)that is not enclosed? 74Til Section 11.B.2.e,Alternative emissions control equipment Disclaimer This document assists operators with determining applicability of certain requirements of the Clean Air Act,its implementing regulations,and Air Quality Control Commission regulations.This document is not a rule or regulation,and the analysis it contains may not apply to a particular situation based upon the individual facts and circumstances.This document does not change or substitute for any law, regulation,or any other legally binding requirement and is not legally enforceable.In the event of any conflict between the language of this document and the language of the Clean Air Act„its implementing regulations,and Air Quality Control Commission regulations,the language of the statute or regulation will control. The use of non-mandatory language such as"recommend,""may,""should," and"can,"is intended to describe APCD interpretations and recommendations.Mandatory terminology such as"must'and"required"are intended to describe controlling requirements under the terms of the Clean Air Act and Air Quality Control Commission regulations,but this document does not establish legally binding requirements in and of itself. inn Cial CDPHE Condensate Storage Tank(s) APEN A` 406, Form APCD-20S CO 1' Air Pollutant Emission Notice(APEN) and Application for Construction Permit Alt sections of this APEN and application must be completed for both new and existing facilities, including APEN updates.An application with missing information may be determined incomplete and may be returned or result in Longer application processing times. You may be charged an additional APEN fee if the APEN is filled out incorrectly or is missing information and requires re-submittal. This APEN is to be used for tanks that store condensate associated with oil and gas industry operations. If your emission source does not fall into this category,there may be a more specific APEN available for your source(e.g. crude oil storage tanks, produced water storage tanks, hydrocarbon liquid loading,etc.).In addition,the General APEN(Form APCD-200)is available if the specialty APEN options will not satisfy your reporting needs.A list of all available APEN forms and associated addendum forms can be found on the Air Pollution Control Division(APCD) website at:www.cotorado.gov/pacific/cdphe/air-permits. This emission notice is valid for five(5)yeas. 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: / / 1 Erf 7 AIRS ID Number: re7, AO) cie)1 [Leave blank unless APCD has already assigned a permit Si and AIRS ID) Section 1 -Administrative Information Company Name: PDC Energy, Inc. Site Name: Thistle Down 31 Sec HZ Site Location Site Location: NESW Sec 31 T5N R64W County: Weld NAICS or SIC Code: 1311 Mailing Address: ,ndude ap Cade) 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.My changes will require additional paperwork. 2 Permits,exemption letters,and any processing invoices wilt be issued by the APCD via e-mail to the address provided. (424 cb caio�.00 Form APCD-2O5 Condensate Storage Tank(s)APEN Revision 7/2018 1 COLD-.«.., Permit Number: lau-` -( -V AIRS ID Number: ill /Ao45/ oot [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 2- Requested Action ❑ NEW permit OR newly-reported emission source QQ Request coverage under traditional construction permit ❑ Request coverage under a General Permit O GP01 O GP08 If General Permit coverage is requested,the General Permit registration fee of$312.50 must be submitted along with the APEN filing fee. -OR- ❑ MODIFICATION to existing permit(check each box below that applies) ❑ Change in equipment O Change company name3 ❑ Change permit limit O Transfer of ownership4 O 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 ❑ Umit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info&Notes: Initial permit request for condensate storage tanks at a new facility 3 For company name change,a completed Company Name Change Certification Form(Form APCD-106)must be submitted. 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: 08/01/2019 For new or reconstructed sources, the projected start-up date is: Normal Hours of Source Operation: 24 hours/day 7 days/week 52 weeks/year Storage tank(s)located at: ❑ exploration&Production(E&P)site O Midstream or Downstream(non E&P)site Will this equipment be operated in any NAAQS nonattainment area? 0 Yes O No Are Flash Emissions anticipated from these storage tanks? 0 Yes O No Is the actual annual average hydrocarbon liquid throughput a 500 bbl/day? ❑ Yes 0 No If"yes", identify the stock tank gas-to-oft ratio: 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 emissions a 6 ton/yr(per storage tank)I 0 Yes ❑ No coLO+•oo Form APCD-205 Condensate Storage Tank(s)APEN - Revision 7/2018 2 I Permit Number: yq ( MRS ID Number: vt,b / co% [Lease blank unless APCO has already assrgned a permit r and AIRS ID] Section 4- Storage Tank(s) Information Actual Annual Amount Requested Annual Permit Limits (bbUyeart (bbl/year) I Condensate Throughput: 11#,479 '4,011 137,376 qt,SlibS From what year is the actual annual amount? Projected Average API gravity of sales oft: 53.9 degrees RVP of sales oil: 11.6 Tank design: ®Fixed roof O Internal floating roof O External floating roof Storage r/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 11 5,918 1/2019 8/2019 Wells Serviced by this Storage Tank or Tank Battery's(E&P Sites On 5f) API Number Name of Well Newly Reported Well 05 -123 -45256 Thistle Down 31G-232 05 - 123 -45257 Thistle Down 31G-332 0 05 • 123 -45746 Thistle Down 31G-402 0 05 • 123 -45254 Thistle Down 31H-202 0 05 • 123 -45255 Thistle Down 31H-232 0 5 Requested values will become permit(Imitations. Requested limit(s)should consider future growth. 6 The E&P Storage Tank APEN Addendum(Form APCD-212)should be completed and attached when additional space is needed to report all wells that are serviced by the equipment reported on this APEN form. Section 5 - Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.35256/-104.59717 Operator Stack Discharge Height Above_ Temp. Flow Rate - Velocity ID No. Ground Level(feet) (°F) - (ACFM) (ft/sec) N/A Indicate the direction of the stack outlet:(check one) ❑Upward 0 Downward O Upward with obstructing raincap ❑Horizontal 0 Other(describe): Indicate the stack opening and size:(check one) ❑Circular Interior stack diameter(Inches): ❑Square/rectangle Interior stack width(inches): Interior stack depth(Inches): ❑Other(describe): COLOI:OO Form APCD-205 Condensate Storage Tank(s)APEN • Revision 7/2018 3 ( � , ::... Permit Number: t tOL1} AIRS ID Number: raj / A.9 00 [leave blank unless APCD has already assx3ned a permit k 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: O 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 4a'&1 x Cimarron 60' ❑r Combustion Device: t on Requested Control Efficiency: 95 Manufacturer Guaranteed Control Efficiency: 98 Minimum Temperature: Waste Gas Heat Content: 2,661 Btu/scf Constant Pilot Light: ❑ Yes O No Pilot Burner Rating: $ 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)? 24.9 psig Describe the separation process between the well and the storage tanks: High/Low Pressure Separator 1lf CiAlOkitaZ p�� COIOUADO Form APCD-205 Condensate Storage Tanks►APEN • Revision 7/2018 4 I ! ,° -**" Permit Number: t_( l, MRS ID Number. 11.s / • SI cO 1 [Leave blank unless APCD has already 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(al reduction): Overall Requested Control Pollutant Description of Control Method(s) Efficiency !%reduction in minions) Enclosed Ensed Combustor 9514 NOx CO HAPS Enclosed Combustors OS% • Other. From what year is the following reported actual annum emissions data? Projected Criteria Pollutant Emissions Inventory Requested Annual Permit Emission Factor7 Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (AP-42, Emissions Emissfonse Emissions Emissions Basis Mfg etc) (Tons/year) (Tons/year) (Tans/year) (Tons/year) V0C ssr�t , ty.�, l .0 �,,,il,µq I;.4>< NOx ii 4M10.004. Ib/MMBtu t 0.1% _ 61Ti 1.it. 1.11. . CO 4)taepc I a'% Ib/MMBtu Ara. L.i1 1..11 t.41 1..44 • 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 0.0126 Ib/bbl ProMax 9t 1.% `V.L Toluene 108883 0.0160. Ib/bbl ProMax (j 1 , {p 4.0.1 Ethylbenzene 100414 0.0004° lb/bbl ProMax i.5(ts"•) Xylene 1330207 0,0057° Ib/bbl ProMax `+$1.'{ ZI.lr n-Hexane 110543 0.1293 Ib/bbl ProMax Q1;(, S.i► 2'2'4• 54Q841 1.91 E-04. Ib/bbl ProMax IL(.y cam,) col Co..) Trimethylpentane _ s Requested values will become permit limitations.Requested limit(s)should consider future growth. 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. °Annual emissions fees will be based on actual controlled emissions reported.If source has not yet started operating,leave blank. Hai04104 tuat4) C04011:00 Form APCD-2O5 Condensate Storage Tank(s)APEN - Revision 7/2018 5 I f©©� Permit Number: oe i©n AIRS ID Number: il3 AC 49 OO1 [Leave blank unless APCD has already assigned a permit 0 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. Ste-- i0/2.1/2©/9 Signa of Legally Authorized Person (not a vendor or consultant) Date Jac Starr Air Quality Representative Name(print) Title Check the appropriate box to request a copy of the: Draft permit prior to issuance E3 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.Rov/cdphe/apcd ceio*•oo Form APCD-205 Condensate Storage Tanklsi APEN - Revision 7/2018 6 I AV °"`:.a 0o E&P Storage Tank Air Pollutant Emissions Notice(APEN)Addendum Form' Company Name: PDC Energy,Inc. Source Name: Thistle Down 31 Sec HZ • Emissions Source AIRS II)2 121./.601 /co Wells Services by this Storage Tank or Tank Battery (E&P Sites Only) API Number Name of Well Newly Reported Well 05-123-45258 Thistle Down 31H-302 05-123-45260 Thistle Down 31H-312 05.123-45259 Thistle Down 31H-332 05-123-45455 Thistle Down 311-212 El 05-123-45456 Thistle Down 31I-302 O O O O O O _ O O O O O O O O - - ❑ Footnotes: I Attach this addendum to associated APEN form when needed to report additional wells. 2 If this is a newly report source that has not been assigned an AIRS ID by the APCD,enter N/A Form APCD-212 TK-1 Addendum Received 07/06/2020 - : Gas Venting APEN - Form APCD-211 Air Pollutant Emission Notice (APEN) and .w Application Application for Construction Permit All sections of this APEN and application must be completed for both new and existing facilities, including APEN updates. Incomplete APENs will be rejected and will require re-submittal. Your APEN will be rejected if it is filled out incorrectly, is missing information, or lacks payment for the filing fee. The re-submittal will require payment for a new filing fee. This APEN is to be used for gas venting only. Gas venting includes emissions from gas/liquid separators, well head casing, pneumatic pumps, blowdown events, among other events. If your emission unit does not fall into this category, there may be a more specific APEN for your source (e.g. amine sweetening unit, hydrocarbon liquid loading, condensate storage tanks, etc.). In addition, the General APEN (Form APCD-200) is available if the specialty APEN options will not satisfy your reporting needs. A list of all available APEN forms can be found on the Air Pollution Control Division (APCD)website. This emission notice is valid for five (5)years. Submission of a revised APEN is required 30 days prior to expiration of the five-year term, or when a reportable change is made (significant emissions increase, increase production, new equipment, change in fuel type, etc.). See Regulation No. 3, Part A, II.C. for revised APEN requirements. Permit Number: 20WE0603 AIRS ID Number: 1 23 /AOA5 / 008 [Leave blank unless APCD bas already assigned a permit e and ti RS 1D] Section 1 - Administrative Information Company Name': PDC Energy, Inc. Site Name: Thistle Down 31 Sec HZ Site Location Site Location: NESW Sec 31 T5N R64W Weld County: NAICS or SIC Code: 1311 Mailing Address:(Include Zip Code) 1775 Sherman Street, Suite 3000 Denver, CO 80203 Contact Person: Jack Starr Phone Number: (303) 860-5800 E-Mail Address2: Jack.Starr@pdce.com 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. (COLORADO Form APCD-211 Gas Venting APEN - Revision 12:2019 1 x "o Permit Number: 2OWE0603 AIRS ID Number: 123 i A0A5 i 008 [Leave blank unless APCD has already assigned a permit and AIRS ID] Section 2 - Requested Action ❑✓ NEW permit OR newly-reported emission source -OR- ❑ MODIFICATION to existing permit (check each box below that applies) ❑ Change fuel or equipment 0 Change company name3 ❑ Add point to existing permit ❑ Change permit limit ❑ Transfer of ownership's 0 Other(describe below) -OR- ❑ APEN submittal for update only(Note blank APENs will not be accepted) -ADDITIONAL PERMIT ACTIONS- ▪ Limit Hazardous Air Pollutants(HAPs)with a federally-enforceable limit on Potential To Emit(PTE) Additional Info Et Notes: APEN submittal for emissions associated with surge vessel vapor recovery unit(VRU)downtime. Emissions calculated using the condensate storage tank ProMax simulation and emission factors 3 For company name change,a completed Company Name Change Certification Form (Form APCD-106)must be submitted. 4 For transfer of ownership, a completed Transfer of Ownership Certification Form (Form APCD-104)must be submitted. Section 3 - General Information General description of equipment and purpose: Surge vessel VRU downtime emissions Company equipment Identification No. (optional): Surge Vessel For existing sources, operation began on: 8/1/2019 For new, modified, or reconstructed sources, the projected start-up date is: ❑✓ Check this box if operating hours are 8,760 hours per year; if fewer, fill out the fields below: Normal Hours of Source Operation: hours/day days/week weeks/year Will this equipment be operated in any NAAQS Yes 0 No nonattainment area? Is this equipment located at a stationary source that is considered a Major Source of(HAP) Emissions? ❑ Yes 0 No Is this equipment subject to Colorado Regulation No. 7, ❑✓ Yes ❑ No Section XVII.G? COLORADO 2 Form APCD-211 Gas Venting APEN - Revision 12/2019 x.aen a e"wo"menc Permit Number: 20WE0603 AIRS ID Number: 123 iA0A5i 008 [Leave btank unless APCD has already assigned a permit ss and AIRS ID] Section 4 - Process Equipment Information ❑✓ Gas/Liquid Separator ❑ Well Head Casing O Pneumatic Pump Make: Model: Serial#: Capacity: gal/min O Compressor Rod Packing Make: Model: #of Pistons: Leak Rate: Scf/hr/pist ❑ Blowdown Events #of Events/year: Volume per event: MMscf/event O Other Description: If you are requesting uncontrolled VOC emissions greater than 100 tpy for a gas/liquid separator, you must use Gas Venting as a process parameter. Are requested uncontrolled VOC emissions greater than 100 tpy? ❑✓ Yes O No Vent Value: 2 661 BTU/SCF Gas Venting Heating Valuue:: , Process Parameters5: q 2.580 y 2.150 MMSCF/year Requested: MMSCF/year Actual: MMSCF/ ear -OR- Liquid Throughput Process Parameters5 Requested: 45,792 bbl/year Actual: 38,160 bbl/year Molecular Weight: 47.3779 VOC (Weight%) 83.65 Benzene (Weight%) 0.18 Vented Gas Toluene (Weight%) 0.23 Properties: Ethylbenzene(Weight%) 0.006 Xylene (Weight%) 0.08 n-Hexane (Weight%) 1.84 2,2,4-Trimethylpentane (Weight%) 0.003 Additional Required Documentation: ❑✓ Attach a representative gas analysis(including BTEX Et n-Hexane, temperature, and pressure) ❑ Attach a representative pressurized extended liquids analysis (including BTEX& n-Hexane, temperature, and pressure) 5 Requested values will become permit limitations or will be evaluated for exempt status, as applicable, and should consider future process growth. Requested values are required on all APENs,including APEN updates. ;COLORADO Form APCD-211 Gas Venting APEN - Revision 12/2019 3 Redlines per application. (HDS 07/13/2020) Permit Number: 20WE0603 AIRS ID Number: 1 23 /A0A5/ 008 [Leave blank unless APCD has already assigned a permit 4 and AIRS Di Section 5 - Geographical/Stack Information Geographical Coordinates (Latitude/Longitude or UTM) 40.35256/-104.59717 ] Check box if the following information is not applicable to the source because emissions will not be emitted from a stack. If this is the case, the rest of this section may remain blank. Discharge Height Operator Temp. Flow Rate Velocity Above Ground Level Stack ID No. {`F) (ACFM) (ft/sec) (Feet) Indicate the direction of the stack outlet: (check one) o Upward ❑ Downward El Upward with obstructing raincap O Horizontal O Other(describe): Indicate the stack opening and size: (check one) ❑ Circular Interior stack diameter (inches): ❑ Square/rectangle Interior stack width (inches): Interior stack depth (inches): ❑ Other(describe): Section 6 - Control Device Information ❑ Check this box if no emission control equipment or practices are used to reduce emissions, and skip to the next section. Pollutants Controlled: Size: Make/Model: O VRU: Requested Control Efficiency: VRU Downtime or Bypassed: Pollutants Controlled: VOC & HAPs Rating: MMBtu/hr Type: Enclosed Combustors Make/Model: 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: 2,661 Btu/scf Constant Pilot Light: ❑✓ Yes O No Pilot burner Rating: 0.018 MMBtu/hr Pollutants Controlled: O Other: Description: Requested Control Efficiency: % "` nw,.1OR AuDO Form APCD-211 -Gas Venting APEN - Revision 12/201 Permit Number: 20WE0603 AIRS ID Number: 123 /A0A5/ 008 [Leave blank unless APCD has already assigned a permit#and AIRS ID] Section 7 - Criteria Pollutant Emissions Information Attach all emissions calculations and emission factor documentation to this APEN form. Is any emission control equipment or practice used to reduce emissions? 0 Yes ❑ No If yes, describe the control equipment AND state the collection and control efficiencies (report the overall, or combined, values if multiple emission control methods were identified in Section 6): Collection Efficiency Control Efficiency Pollutant Control Equipment Description (%of total emissions captured (%reduction of captured by control equipment) emissions) PM SOx NO. CO VOC Enclosed Combustors 100% 95% HAPs Enclosed Combustors 100% 95% Other: From what year is the following reported actual annual emissions data? Projected Use the following table to report the criteria pollutant emissions from source: Requested Annual Permit Emission Factor Actual Annual Emissions Emission Limit(s)5 Pollutant Source Uncontrolled Controlled Uncontrolled Controlled Uncontrolled Units (A'42, Emissions Emissions& Emissions Emissions Basis Mfg.,etc.) (tons/year) (tons/year) (tons/year) (tons/year) PM SOx NOx 0.1380 lb/MMBtu TCEQ N/A 0.39(DM) N/A 0.47(DM) CO 0.2755 lb/MMBtu TCEQ N/A 0.79(DM) N/A 0.95(DM) VOC 5.8848 Ib/bbl ProMax 112.28 5.61 134.74 6.74 5 Requested values will become permit limitations or will be evaluated for exempt status,as applicable, and should consider future process growth. Requested values are required on all APENs,including APEN updates. 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. Section 8 - Non-Criteria Pollutant Emissions Information Does the emissions source have any uncontrolled actual emissions of non-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 Source Uncontrolled Controlled Chemical Name Uncontrolled Service(CAS) Basis Units (AP-42, Emissions Emissions6 Number Mfg.,etc.) (lbs/year) (lbs/year) Benzene 71432 0.0126 Ib/bbl ProMax 482.17 24.11 Toluene 108883 0.0160 lb/bbl ProMax 609.33 30.47 Ethylbenzene 100414 0.0004 Ib/bbl ProMax 15.01(DM) 0.75(DM) Xylene 1330207 0.0057 Ib/bbl ProMax 216.21(DM) 10.81(DM) n-Hexane 110543 0.1293 Ib/bbl ProMax 4,935.67 246.78 2,2,4-Trimethylpentane 540841 1.91E-04 lb/bbl ProMax 7.27(DM) 0.36(DM) Other: 6 Annual emission fees will be based on actual controlled emissions reported. If source has not yet started operating, provide projected emissions. COLORADO Form APCD 211 Gas Venting APEN Revision 12/2019 5 ; :w. ", Permit tlumlivr: 20WE0603 AIItS Ill homily;: 123 /AU)A ! 008 Sect Ion 9 - Appllcan trortftetIi n I Itrralry trtlliy thnl nll intnnnnU,,n t urtinlmnri lira In nod hrfnnnnilt,n tuhntIllnil with Ihl:nplillt ntlum to cnnq;drle, 1,11*', neat Cntt`p l, 'ii n"iro ml 1 e!ynlly AIILlintirrrl l'ni ,,u inn? n vnntint m i t,n,iltnnt 1 (Into Jack Starr Senior Air Quality Representative I lan1ti twin,) I Itli'• Ghat k Ilia airyttooIola ti u11 tairt9rlu. 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